Section 80G(5) Approval Rejections: 12 ITAT Rulings (June–July 2026)
12 ITAT rulings (June–July 2026) on Section 80G(5) approval rejections: Form 10AB filings, delayed applications, and linked 12A registration issues.
This compilation indexes twelve orders pronounced by various benches of the Income Tax Appellate Tribunal (ITAT) between 29 June 2026 and 9 July 2026, all arising from rejections of applications for approval or renewal of approval under Section 80G(5) of the Income Tax Act, 1961. The rulings span benches at Agra, Surat, Mumbai, Chennai, Dehradun, and Pune. This resource is intended for in-house tax teams, Big-4 associates, law firm researchers, and compliance professionals who need a structured index of recent tribunal activity on Section 80G(5) approval proceedings.
Research index only. This page is a structured case-law reference compiled from tribunal orders. It does not constitute legal or tax advice. Readers should verify each ruling against the full judgment text, check for subsequent stays or reversals, and consult qualified advisors before acting on any information herein.
The statutory framework in one paragraph
Section 80G of the Income Tax Act, 1961 provides a deduction to donors making contributions to approved funds, charitable institutions, and other specified entities. Sub-section (5) of Section 80G prescribes the conditions that an institution or fund must satisfy to be eligible for such approval, including that it must be established in India for a charitable purpose, that its income should not be liable to be included in the total income of the institution under certain provisions, and that it must apply for approval in the prescribed form and manner within the prescribed time. The Finance Act, 2020 and subsequent amendments introduced a regime of fresh registration and approval, requiring eligible entities to apply in Form No. 10AB before specified deadlines, failing which the approval lapses. The Commissioner of Income Tax (Exemptions) is the prescribed authority for granting or rejecting such approvals, and orders passed under Section 80G(5) are appealable before the ITAT.
The 12 rulings
1. Shri Digambar Jain Siddh Kshetre vs CIT Exemption, Agra
- Bench: Income Tax Appellate Tribunal - Agra
- Date: 9 July 2026
- Sections engaged: 12A, 12A(1), 12A(1)(ac), 154, 287, 80, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed by the assessee against an impugned order dated 05.03.2026 passed by the Commissioner of Income Tax (Exemption), Lucknow, in ITA No. 457 & 458/Agr/2026 for A.Y. 2026-27, wherein the CIT(E) rejected the assessee's application. The two appeals involved almost identical facts and were decided by a common order; the facts of ITA No. 457/Agr/2026 were treated as the lead matter per the source preview.
2. Bhandut Seva Charitable Trust,Surat vs CIT(Exemption)Ahmedabad, Ahmedabad
- Bench: Income Tax Appellate Tribunal - Surat
- Date: 7 July 2026
- Sections engaged: 12A, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Surat bench and is listed among a group of appeals involving charitable trusts from the Surat and Valsad regions, all arrayed against CIT(Exemption), Ahmedabad. The source preview identifies the matter as ITA No. 858/SRT/2026 and records the assessee's PAN as AABTB9538K; the substantive grounds are not further elaborated in the available source preview.
3. Hiragauri And Dr Chaturdas Dadia vs ITO Ecem Ward 1(3), Mumbai
- Bench: Income Tax Appellate Tribunal - Mumbai
- Date: 6 July 2026
- Sections engaged: 10, 12A, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Two appeals — ITA 2606/MUM/2026 and ITA 2655/MUM/2026 — were filed by Hiragauri and Dr. Chaturdas Dadia Charitable Trust (PAN: AAATH0245C) for Assessment Year 2026-27. Per the source preview, the appeals arise out of orders passed against the assessee; the substantive grounds of challenge are not elaborated beyond the caption in the available text preview.
4. Pasikulam Development Trust,Chennai vs CIT, Exemptions,, Chennai
- Bench: Income Tax Appellate Tribunal - Chennai
- Date: 6 July 2026
- Sections engaged: 2(15), 80G, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal in ITA No. 3981/Chny/2025 was preferred by the assessee challenging the order dated 29.09.2025 passed by the Commissioner of Income Tax (Exemptions), Chennai under Section 80G(5), by which the CIT(E) rejected the assessee's application in Form No. 10AB seeking approval under Section 80G of the Act. The assessee is located at Sri Kanchi Mahaswami Vidya Mandir Campus, Chennai, and carries PAN AAETP5767H per the source preview.
5. The Bombay Patel Welfare vs CIT (Exemption), Mumbai
- Bench: Income Tax Appellate Tribunal - Mumbai
- Date: 3 July 2026
- Sections engaged: 12A, 80G, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal in ITA No. 1944/Mum/2026 (Assessment Year 2026-27) was preferred by the assessee against the order dated 31.12.2025 passed by the CIT(Exemptions), Mumbai in Form No. 10AD, whereby the CIT(E) rejected the application filed in Form No. 10AB under clause (iii) of the first proviso to Section 80G(5) seeking regular approval under Section 80G. The assessee is stated to be a charitable society registered under the Bombay Public Trusts Act, 1950 (PAN: AAATT0800F), per the source preview.
6. Manorama Dabral Jan Kalyan vs Exemption Ward, Dehradun
- Bench: Income Tax Appellate Tribunal - Dehradun
- Date: 3 July 2026
- Sections engaged: 80G, 80G(5), 80G(5)(i), 80G(5)(ii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The matter in ITA No. 233/DDN/2026 (Assessment Year 2025-26) arises from an order dated 25.02.2026 passed by the CIT(Exemptions), Lucknow under Section 80G(5), rejecting the assessee's application. Per the source preview, the order recorded a finding that the trust had been approved within the stipulated time limit under Section 80G(5) by CPC, and the assessee (PAN: AAFAM0578D) approached the ITAT challenging the rejection on the grounds set out in the appeal.
7. 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: The appeal in ITA No. 239/DDN/2026 arises from an order dated 06.03.2026 passed by the CIT(E), Lucknow under Section 80G(5), whereby the application of the assessee for grant of registration was rejected on account of delayed filing of the requisite form by more than one year. The assessee (PAN: AAPTS0371R), based in Jwalapur, Haridwar, Uttarakhand, approached the ITAT challenging this action per the source preview.
8. 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: The appeal in ITA No. 212/DDN/2026 (Assessment Year 2025-26) arises from an order dated 09.03.2026 passed by the CIT(Exemptions), Lucknow under Section 80G(5), in which the application of the assessee was rejected on account of delay in filing of Form 10AB. Per the source preview, on the last date of hearing none appeared on behalf of the assessee (PAN: AAATA1726H), but the tribunal decided to proceed with adjudication with the assistance of the Departmental Representative.
9. 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 No. 3769/Mum/2026 and ITA No. 3768/Mum/2026 — were filed by the assessee (PAN: AAATT5826H) against two separate orders both dated 26.03.2026 passed by the CIT(Exemptions), Mumbai, for Assessment Year 2026-27. Per the source preview, the appeals arise from a common set of facts and were disposed of by a consolidated order; ITA No. 3768/Mum/2026 is directed against an order passed under Section 12AB of the Act whereby the registration was refused, and ITA No. 3769/Mum/2026 relates to the connected Section 80G(5) approval matter.
10. Association Of Indian Schools,Mumbai vs CIT (Exemptions), Mumbai, Mumbai
- Bench: Income Tax Appellate Tribunal - Mumbai
- Date: 30 June 2026
- Sections engaged: 12A, 12A(1), 80G, 80G(5), 80G(5)(i)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal in ITA No. 4471/Mum/2026 (Assessment Year 2025-26 to 2029-30) is directed against the order dated 06.02.2026 passed by the CIT(Exemptions), Mumbai in Form No. 10AD, whereby the application filed by the assessee in Form No. 10AB on 30.09.2025 seeking approval under clause (ii) of the first proviso to Section 80G(5) was rejected. Per the source preview, the assessee (PAN: AAEAA2272R) contended, in substance, that the CIT(E) erred in rejecting the Section 80G application merely on the basis of rejection of the assessee's application for registration.
11. Maharani Devi Ahilyabai Holkar vs CIT (Exemption), Pune
- Bench: Income Tax Appellate Tribunal - Pune
- Date: 29 June 2026
- Sections engaged: 10, 129, 12A, 36A, 80G, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal in ITA No. 2636/PUN/2025 (Assessment Year 2026-27) is directed against the order dated 23.09.2025 of the CIT(Exemption), Pune rejecting the assessee's application for grant of approval under Section 80G. Per the source preview, the assessee — Maharani Devi Ahilyabai Holkar Education Society, Sangli (PAN: AACTM5788M) — had filed an application in Form No. 10AB under sub-clause (B) of (iv) of the first proviso to sub-section (5) of Section 80G on 28.03.2025, and the CIT(E) sought to verify the genuineness of the activities of the trust before deciding the application.
12. Maharashtra Lohita Seva Mandal,Mumbai vs CIT Exemption, Mumbai
- Bench: Income Tax Appellate Tribunal - Mumbai
- Date: 29 June 2026
- Sections engaged: 12A, 12A(1)(ac), 80G, 80G(5), 80G(5)(i)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Two appeals — ITA No. 3634/Mum/2026 and ITA No. 3635/Mum/2026 — were filed by the assessee (PAN: AAATM5251F) against two separate orders both dated 28.02.2026 passed by the CIT(Exemptions), Mumbai in Form No. 10AD: one rejecting the application for renewal of registration under Section 12AB, and the other rejecting the application for renewal of approval under Section 80G(5). Per the source preview, since the issues in both appeals arose from a common set of facts, they were taken up together.
Patterns across these 12 rulings
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Form 10AB as the near-universal procedural vehicle. Across the rulings where the source preview is sufficiently detailed — cases 4, 5, 10, 11, and 12 — the immediate trigger for the CIT(E)'s rejection order is the assessee's application filed in Form No. 10AB seeking approval or renewal of approval under Section 80G(5). The Form 10AB / Form 10AD framework appears consistently as the operative procedural pair in these proceedings.
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Delayed filing as a standalone rejection ground. In at least two matters from the Dehradun bench — cases 7 and 8 — the CIT(E)'s rejection order was explicitly grounded on the delayed filing of the requisite form, with case 7 specifying that the delay exceeded one year. This indicates that timely filing of Form 10AB is being strictly enforced at the CIT(E) stage.
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Linked rejection of registration and Section 80G(5) approval. Cases 9, 10, and 12 all feature parallel rejections — one order refusing registration under Section 12AB and a companion order refusing Section 80G(5) approval — arising from the same set of facts and heard together. This pattern indicates that the fate of the Section 80G(5) approval is being treated by the CIT(E) as consequential upon or co-dependent with the registration status.
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Geographic spread with concentration in Mumbai. Of the twelve rulings, five were pronounced by ITAT Mumbai benches (cases 3, 5, 9, 10, 12), three by the Dehradun bench (cases 6, 7, 8), and one each by ITAT Agra, Surat, Chennai, and Pune. The Mumbai concentration may reflect the volume of charitable institutions registered in Maharashtra that are currently navigating the re-approval cycle.
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Outcome data unavailable at the source level. Across all twelve rulings, the structured outcome field records "Outcome not specified in source," meaning the dispositive direction — whether the ITAT allowed, dismissed, or remanded each appeal — cannot be confirmed from the available data. Researchers should access the full judgment text on indiankanoon.org or the official ITAT portal to determine the operative holding in each case before relying on any ruling for compliance or advisory purposes.
How to use this compilation
This index is structured to support initial identification and triage of relevant ITAT precedents on Section 80G(5) approval proceedings. Each case entry provides the tribunal, bench, pronouncement date, sections engaged, and the procedural ground as reflected in the source preview. Researchers should treat this compilation as a starting point: the full judgment text must be retrieved and read before any ruling is cited in submissions, opinions, or compliance positions. Full texts are available on indiankanoon.org and the official ITAT e-filing and order portal.
Before relying on any ruling indexed here, researchers should check whether the order has been challenged before the relevant High Court or the Supreme Court, whether a stay has been granted against the ITAT's direction, and whether any subsequent CBDT circular or instruction has modified the regulatory position on Form 10AB timelines or the conditions for Section 80G(5) approval. The law on re-registration and re-approval of charitable institutions has been subject to frequent legislative and administrative changes since 2020, and the applicability of any particular ruling depends on the specific facts, assessment year, and the clause of Section 80G(5) under which the application was made.
Researchers using this compilation for cross-jurisdictional comparison across ITAT benches should note that the bench composition, the specific clause of Section 80G(5) invoked, and the nature of the charitable activity may all affect the outcome. Citations extracted from this index should be verified for accuracy against the original order header, including ITA number, PAN, and date of pronouncement, before being included in any legal document.
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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