Section 12A(1)(ac) Registration: 12 ITAT Rulings on Form 10AB Rejections (2026)
A structured index of 12 ITAT rulings from June–July 2026 on Section 12A(1)(ac) Form 10AB registration and renewal rejections for charitable and religious trusts.
This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings pronounced between 30 June and 3 July 2026, all arising from orders passed by Commissioners of Income Tax (Exemptions) rejecting or refusing to grant registration or renewal under the provisions of the Income Tax Act, 1961 that include Section 12A(1)(ac). The rulings span multiple ITAT benches across India — Delhi, Dehradun, Chandigarh, Raipur, Pune, Indore, Jaipur, and Mumbai — and are relevant to tax practitioners, in-house legal and compliance teams of charitable and religious organisations, and Big-4 or law firm researchers advising the exempt-entity sector.
Research index only. This page is a structured case-law reference for legal research purposes. It does not constitute legal advice, tax advice, or any professional opinion on the merits of any dispute. Readers must consult the full text of each judgment and seek independent professional advice before acting on any information contained herein.
The statutory framework in one paragraph
Section 12A of the Income Tax Act, 1961 prescribes the conditions that a charitable or religious trust or institution must satisfy in order to claim the exemptions available under Sections 11 and 12. Section 12A(1)(ac), inserted by the Finance Act, 2020 with effect from 1 April 2021 as part of a comprehensive re-registration regime, requires every existing registered trust or institution — and every new applicant — to make a fresh application for registration in the prescribed form (Form No. 10AB) within the time limits and in the manner specified. The provision operates alongside Section 12AB, which governs the procedure for grant of registration by the Principal Commissioner or Commissioner, and replaces the earlier registration framework under the erstwhile Section 12AA. Non-compliance with the filing requirements under Section 12A(1)(ac) — including delayed filing of Form 10AB — can result in rejection of the registration or renewal application by the concerned CIT (Exemptions), with downstream consequences for the entity's exempt status under Sections 11 and 12.
The 12 rulings
1. Mam Chand Premwati Charitable vs Commissioner Of Income Tax
- Bench: Income Tax Appellate Tribunal - Delhi
- Date: 3 July 2026
- Sections engaged: 12A, 12A(1)(ac), 13
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Delhi (ITA No. 5261/Del/2026) for Assessment Year 2027-28, directed against an order dated 09.05.2026 of the CIT (Exemptions), New Delhi. Per the source preview, the CIT(E) rejected the assessee's application dated 19.09.2025 filed in Form 10AB on account of non-filing of relevant details and/or information; the appeal was heard on 23.06.2026 with none appearing on behalf of the assessee.
2. Samvedna-Connecting Souls,Hardwar vs Income Tax Officer (Exemption)
- Bench: Income Tax Appellate Tribunal - Dehradun
- Date: 3 July 2026
- Sections engaged: 10A(8), 119, 12A, 12A(1)(ac), 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: This appeal (ITA No. 239/DDN/2026) arises from an order dated 06.03.2026 passed by the CIT(E)-Lucknow, whereby the assessee's application for grant of registration was rejected on account of delayed filing of the requisite form by more than one year. The aggrieved assessee approached the ITAT and reserved the right to add, alter, amend, or withdraw grounds of appeal per the source preview.
3. Aurovalley Ashram Society,Dehradun vs CIT (Exemption), Lucknow
- Bench: Income Tax Appellate Tribunal - Dehradun
- Date: 3 July 2026
- Sections engaged: 10A(8), 119, 12A, 12A(1)(ac), 80G, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: This appeal (ITA No. 212/DDN/2026) for Assessment Year 2025-26 arises from an order dated 09.03.2026 passed by the CIT(Exemptions), Lucknow, whereby the assessee's application was rejected on account of delayed filing of Form 10AB. On the last date of hearing, none appeared on behalf of the assessee, but the tribunal decided to proceed with adjudication with the assistance of the Departmental Representative per the source preview.
4. Shakuntala Surana Charitable Trust vs CIT( Exemption), Bhopal, Bhopal
- Bench: Income Tax Appellate Tribunal - Raipur
- Date: 2 July 2026
- Sections engaged: 12(1)(ac), 12A(1)(ac)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 431/RPR/2026) was filed before the ITAT Raipur and is directed against the order dated 21.03.2026 of the CIT(Exemption), Bhopal, rejecting the renewal of registration under the relevant provisions of the Income Tax Act, 1961. Per the source preview, the sole issue raised across five grounds of appeal revolves around the rejection of the assessee's application for renewal of registration; none appeared on behalf of the assessee at the time of hearing.
5. Ellora Multipurpose vs CIT(Exemption), Pune
- Bench: Income Tax Appellate Tribunal - Pune
- Date: 1 July 2026
- Sections engaged: 12A, 12A(1)(ac)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Two appeals (ITA Nos. 821/PUN/2025 and 822/PUN/2025) were filed for Assessment Year 2025-26 against separate orders both dated 28.02.2025 of the CIT(Exemption), Pune, rejecting the assessee's applications for grant of registration and related approval. Per the source preview, both appeals were heard together and disposed of by a common order for the sake of convenience; the appeal in ITA No. 822/PUN/2025 specifically challenged the rejection of the application for registration.
6. Vidya Bharti Sanskriti Shiksha vs Commissioner Of Income Tax
- Bench: Income Tax Appellate Tribunal - Chandigarh
- Date: 1 July 2026
- Sections engaged: 12A, 12A(1)(ac), 2(15)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 925/Chd/2026) for Assessment Year 2026-27 was preferred against an order dated 28.02.2026 passed by the CIT(Exemptions), Chandigarh, whereby the application filed by the assessee in Form No. 10AB seeking registration under the relevant provisions of the Income Tax Act, 1961 was rejected. Per the source preview, the assessee had filed an application under Section 12A(1)(ac) of the Act.
7. Strategic Institute For Public Health vs CIT (Exemptions), Chandigarh
- Bench: Income Tax Appellate Tribunal - Chandigarh
- Date: 1 July 2026
- Sections engaged: 12A, 12A(1)(ac)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 654/Chd/2026) for Assessment Year 2027-28 was preferred against an order dated 06.03.2026 passed by the CIT(Exemptions), Chandigarh, whereby the application filed by the assessee in Form No. 10AB under Section 12A(1)(ac)(ii) of the Income Tax Act, 1961 seeking registration was rejected. Per the source preview, the assessee — Strategic Institute for Public Health Education and Research (SIPHER) — is stated to be engaged in charitable activities.
8. Green Land Educational vs CIT(Exemptions) , Chandigarh
- Bench: Income Tax Appellate Tribunal - Chandigarh
- Date: 1 July 2026
- Sections engaged: 12A, 12A(1)(ac), 13, 2(15)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 157/Chd/2025) was preferred against the order dated 02.12.2024 passed by the CIT(Exemptions), Chandigarh, whereby the application filed by the assessee society for grant of registration was rejected. Per the source preview, the assessee society had filed an application in Form No. 10AB and, during the course of proceedings, the CIT(Exemptions) noticed that the material available on record was insufficient for examining the matter.
9. Akhil Bhartiya Shri Swami vs CIT(Exemption) Bhopal, Bhopal
- Bench: Income Tax Appellate Tribunal - Indore
- Date: 30 June 2026
- Sections engaged: 10, 11, 12, 12A, 12A(1)(ac), 12A(1)(i), 253
- Outcome: Outcome not specified in source
- Procedural / substantive ground: This appeal (ITA No. 837/Ind/2025) was filed before the ITAT Indore under Section 253 of the Income Tax Act, 1961, against the impugned order bearing reference ITBA/EXM/F/EXM45/2025-26/1077318420(1) dated 21.06.2025 passed by the CIT(E). Per the source preview, the assessee is a "Nyas" (trust) incorporated on 26.03.2021, and the appeal arises from the CIT(E)'s order in the context of registration proceedings.
10. Jamna Lal Kani Ram Bajaj vs CIT Exemption, Jaipur, Jaipur
- Bench: Income Tax Appellate Tribunal - Jaipur
- Date: 30 June 2026
- Sections engaged: 12A(1)(ac), 12A(4)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: This appeal (I.T.A. No. 748/JPR/2026) for Assessment Year 2026-27 was filed against the order of the CIT(E), Jaipur, dated 23/01/2026, rejecting the assessee's application for registration dated 29/09/2025 filed in Form 10AB. Per the source preview, the assessee's ground of appeal contends that the CIT(Exemption), Jaipur erred in rejecting the Form 10AB application by considering it infructuous on the basis that the assessee was required to file for renewal by a different route.
11. Tulsi Eye Hospital,Mumbai vs Exem Ward 2(4), Mumbai
- Bench: Income Tax Appellate Tribunal - Mumbai
- Date: 30 June 2026
- Sections engaged: 12(4)(f), 12A, 12A(1)(ac), 16(2), 80G, 80G(5), 80G(5)(i)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Two appeals (ITA Nos. 3769/Mum/2026 and 3768/Mum/2026) for Assessment Year 2026-27 were filed against two separate orders both dated 26.03.2026 passed by the CIT(Exemptions), Mumbai. Per the source preview, since the issues in both appeals arose from a common set of facts, they were heard together and disposed of by a consolidated order; ITA No. 3768/Mum/2026 is directed against the order passed by the CIT(E) under the relevant provisions of the Income Tax Act, 1961.
12. The Radiology Education vs Commissioner Of Income Tax
- Bench: Income Tax Appellate Tribunal - Mumbai
- Date: 30 June 2026
- Sections engaged: 10, 12A, 12A(1)(ac), 80G, 80G(5)(i)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Two appeals (ITA Nos. 3700/Mum/2026 and 3701/Mum/2026) for Assessment Year 2026-27 arise from two separate orders both dated 31.01.2026 passed by the CIT(Exemptions), Mumbai. Per the source preview, since the appeals concern the same assessee and involve common facts arising out of connected proceedings, they were heard together and disposed of by a common order; ITA No. 3701/Mum/2026 is directed against the order dated 31.01.2026 passed by the CIT(E) in Form No. 10AD in respect of the assessee's application in Form No. 10AB.
Patterns across these 12 rulings
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Form 10AB rejection as the uniform trigger. Across all twelve cases, the first-order dispute is an order of a CIT (Exemptions) rejecting an application filed in Form No. 10AB — whether for fresh registration, renewal, or approval. The volume and geographic spread of these cases (Delhi, Dehradun, Chandigarh, Raipur, Pune, Indore, Jaipur, Mumbai) indicates that Form 10AB rejection is a prevalent compliance friction point for charitable and religious entities nationwide.
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Delayed filing as a recurring ground for rejection. In at least two cases (Cases 2 and 3 — Samvedna-Connecting Souls and Aurovalley Ashram Society), the source previews explicitly identify delayed filing of the requisite form by more than one year as the stated ground for the CIT(E)'s rejection order. This pattern suggests that time-limit compliance is a structurally significant issue in the post-2021 re-registration regime.
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Non-representation of appellants before the tribunal. In multiple cases — including Cases 1 (Mam Chand Premwati Charitable), 3 (Aurovalley Ashram Society), and 4 (Shakuntala Surana Charitable Trust) — none appeared on behalf of the assessee at the time of hearing before the ITAT, yet the tribunal proceeded with adjudication. This signals that tribunals across benches are willing to dispose of such matters on merits or on the basis of available records even in the absence of appellant representation.
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Consolidated disposal of multiple appeals in a single order. In Cases 5 (Ellora Multipurpose), 11 (Tulsi Eye Hospital), and 12 (The Radiology Education), the source previews indicate that two related appeals per assessee were heard together and disposed of by a common order. This reflects a consistent tribunal practice of consolidating registration and related approval challenges where they arise from connected facts.
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Broad sectoral and geographic spread within a narrow time window. All twelve rulings were pronounced within a four-day window (30 June – 3 July 2026), spanning appellants that include educational societies, ashrams, charitable trusts, eye hospitals, a radiology education foundation, and a public health research institute across eight ITAT benches. This concentration indicates a systemic backlog of Form 10AB-related disputes that reached the appellate stage simultaneously, consistent with the staggered deadlines introduced by the re-registration regime post-Finance Act 2020.
How to use this compilation
This index is intended as a starting point for legal and tax research. Each case entry identifies the tribunal bench, date, sections engaged, and — where the source preview supports it — the procedural or substantive ground that led to the appeal. Researchers should treat the "Procedural / substantive ground" notes as summaries of information visible in publicly available order previews, not as complete statements of the tribunal's reasoning or final holding. The outcome field for all cases in this compilation reflects the data available in the source corpus at the time of publication; where the outcome is recorded as "Outcome not specified in source," researchers must retrieve the full text of the order from the tribunal's official portal or indiankanoon.org to ascertain the operative direction (e.g., whether the appeal was allowed, dismissed, or remanded).
Before relying on any ruling listed here, researchers should verify: (a) whether the full order has been uploaded and is consistent with the preview text; (b) whether any stay, rectification, or higher-court proceeding has been filed or decided in respect of the ruling; and (c) whether any CBDT circular, instruction, or notification issued after the date of the ruling bears on the legal position under Section 12A(1)(ac) or the Form 10AB procedure. Tax law in this area has been subject to repeated legislative amendment and administrative clarification since 2020, and the applicable time limits and procedural requirements may have been modified by subsequent CBDT notifications.
This compilation does not analyse the correctness of the CIT(E) orders under challenge or the strength of the grounds of appeal raised by any assessee. It also does not compare outcomes across cases, given that the outcome field is not populated in the source data for any of the twelve cases covered. Researchers engaged in advising clients on registration or renewal matters under Section 12A(1)(ac) should access the complete orders, examine the specific facts and grounds in each case, and independently verify the current state of the law before drawing any conclusions from this index.
Source
All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.
Rangoli Bansal
Editorial Reviewer & CA Finalist
CA Finalist (ICAI), B.Com (Hons.) Delhi University. 7+ years across audit, internal controls, SOX 404, ICFR, RCSA, and GRC. Hands-on experience with GST and income-tax compliance filings, statutory audit, and internal audit. Editorial reviewer for TaxNoticeAI's case-law content.
Disclaimer: The information provided is for educational and informational purposes only and should not be construed as legal or tax advice. AI-generated content is a draft for professional review — always verify with applicable laws, circulars, and case law before filing. Consult a qualified Chartered Accountant or tax professional before acting on any information presented here.
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