Section 80G Registration & Deduction: 12 Recent ITAT and HC Rulings (2026)
A structured index of 12 recent ITAT and High Court rulings on Section 80G registration, approval denial, and deduction disputes under the Income Tax Act, 1961 — for tax researchers.
This compilation indexes 12 recent rulings — from various benches of the Income Tax Appellate Tribunal and the Madras High Court — that engage Section 80G of the Income Tax Act, 1961. The rulings span the period June 10–24, 2026, and collectively cover a broad range of disputes: denial of registration or approval under Section 80G, deduction claims by donors, and intersecting issues with Section 12A/12AB registration. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citable starting point for further primary-source research.
Research index only. This page is a structured case-law reference compiled from the TaxNoticeAI legal corpus. Nothing on this page constitutes legal or tax advice. Readers must verify all information against the full text of the original judgment before placing reliance on it.
The statutory framework in one paragraph
Section 80G of the Income Tax Act, 1961 provides for deductions to donors who make contributions to specified funds, charitable institutions, and other approved entities. The section prescribes the conditions for approval of institutions (under sub-sections such as 80G(5) and 80G(5)(ii)), the categories of funds and institutions whose donations qualify for deduction (under 80G(2) and its sub-clauses), and the quantum of deduction available to the donor (under 80G(1)). Institutions seeking to offer their donors a tax deduction benefit are required to obtain approval from the Commissioner of Income Tax (Exemptions), and applications for such approval are made in the prescribed form (currently Form No. 10AB under the amended regime). The 2020–2021 legislative amendments significantly restructured the registration and approval framework for charitable trusts and institutions, linking Section 80G approval closely to registration under Sections 12A/12AB, and requiring periodic renewal.
The 12 rulings
1. Chokshi Natvarlal Vachhracharitable vs ITO Exemption Ward 2 , Rajkot
- Bench: Income Tax Appellate Tribunal - Rajkot
- Date: 24 June 2026
- Sections engaged: 12A, 80G
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Rajkot as ITA Nos. 375 & 376/RJT/2026, concerning Assessment Year 2026-27. Per the source preview, the assessee is a charitable trust incorporated on 02.03.2000 and registered under the Bombay Public Trust Act (Registration No. E-4460), holding registration under Section 12A and approval under Section 80G since inception, with regularly filed returns and duly audited accounts. The full substantive ground and outcome are not discernible from the source preview available.
2. Essa Ahmed Sait And Rukiya Bai Memorial vs Nil
- Bench: Madras High Court
- Date: 22 June 2026
- Sections engaged: 12A, 80G, 92(1)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: This matter was taken up before the Madras High Court as C.S. No. 260 of 2025. Per the source preview, the civil suit was filed under Section 92(1) of the Code of Civil Procedure, seeking the court's permission for the trust to sell trust property in favour of an intending purchaser. The references to Sections 12A and 80G appear in the context of the trust's identity and registration; the primary prayer as recorded in the preview is for permission to sell trust property, and the full substantive outcome is not discernible from the source preview available.
3. DCIT, Circle-7(1), Delhi vs Ernst & Young Services Private Limited
- Bench: Income Tax Appellate Tribunal - Delhi
- Date: 16 June 2026
- Sections engaged: 12A, 37(1), 80G, 80G(1), 80G(2), 80G(2)(a)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed by the Revenue before the ITAT Delhi as ITA No. 1389/Del/2025, arising out of an assessment order for Assessment Year 2020-21, against the order of the CIT(A)-NFAC in Appeal No. NFAC/2019-20/10192313. Per the source preview, the assessee company is engaged in providing Business Centre Services and Business Support Services at various locations in India, and had filed its return of income on 14.02.2021. The substantive grounds relating to Sections 80G(1), 80G(2), and 80G(2)(a) are not further detailed in the source preview available.
4. Asian Paints Ltd vs The Assistant Commissioner Of Income
- Bench: Bombay High Court
- Date: 15 June 2026
- Sections engaged: 142(1), 143(3), 147, 148, 80G
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The matter came before the Bombay High Court as Writ Petition No. 1683 of 2022. Per the source preview, the petitioner challenges a notice dated March 27, 2021 issued under Section 148 proposing to reopen the assessment for Assessment Year 2017-18, as well as an order dated February 16, 2022 rejecting the petitioner's objections against reopening. The petitioner is a public limited company engaged in the manufacture and sale of paints, varnishes, primers, and related products; the connection to Section 80G and the full substantive outcome are not further detailed in the source preview available.
5. Shri Jain Swetamber Terapanthi Sabha vs Income Tax Officer, Ward-4(1), Raipur
- Bench: Income Tax Appellate Tribunal - Raipur
- Date: 15 June 2026
- Sections engaged: 11, 12A, 80G, 80G(5), 80G(5)(ii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Raipur as ITA No. 154/RPR/2026, directed against an order dated 15.12.2025 of the Commissioner of Income Tax (Exemption), Bhopal, rejecting the assessee's request for approval. Per the source preview, the order includes a table of religious expenses versus total expenses across financial years 2022-23, 2023-24, and 2024-25, suggesting the proportionality of religious expenditure relative to total expenditure was a relevant consideration in the approval proceedings. The full substantive grounds and outcome are not discernible from the source preview available.
6. Rotary Club Of Rajkot Midtown vs The Commisioner Of Income Tax-
- Bench: Income Tax Appellate Tribunal - Rajkot
- Date: 12 June 2026
- Sections engaged: 12A, 80G, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeals were filed before the ITAT Rajkot as ITA Nos. 710 and 711/Rjt/2026, against orders dated 07.03.2026 passed by the CIT (Exemption), Ahmedabad, denying registration under the relevant provisions of the Act. Per the source preview, the assessee had filed applications in Form No. 10AB seeking registration under the applicable sections, and the CIT(E) gave a single opportunity of hearing on 11.02.2026, calling for details of activities and documents; however, the full basis for the denial and the tribunal's final ruling are not discernible from the source preview available.
7. Arun Pratap Singh,Gurgaon vs Income Tax Officer, New Delhi
- Bench: Income Tax Appellate Tribunal - Delhi
- Date: 12 June 2026
- Sections engaged: 115B, 80G
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Delhi as ITA No. 1134/DEL/2026 for Assessment Year 2019-20, directed against the order of the CIT(A)/NFAC dated 30.01.2026. Per the source preview, the assessee is a salaried individual who appeared in person and had made a donation of Rs. 3 lacs to a political party, 'Rashtriya Samajwadi Party (Secular)', through NEFT, supported by a valid donation receipt; the Assessing Officer had disallowed the deduction claimed and also made an adhoc addition under a separate provision. The full substantive grounds pertaining to Sections 115B and 80G and the final outcome are not discernible from the source preview available.
8. Shri Mirambika Trust,Ahmedabad vs Commissioner Of Income Tax Exemptions
- Bench: Income Tax Appellate Tribunal - Ahmedabad
- Date: 12 June 2026
- Sections engaged: 12A, 80G, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeals were filed before the ITAT Ahmedabad as ITA Nos. 1352 and 1353/AHD/2026 for Assessment Year 2025-2026, as two separate appeals by the same assessee-trust against two separate orders passed by the CIT(E), Ahmedabad, denying registration under Section 12A/12AB and the approval under Section 80G. Per the source preview, the first appeal (ITA No. 1352/AHD/2026) challenged an order dated 09/03/2026; the full substantive grounds and final outcome are not discernible from the source preview available.
9. Mahesh Upendra Majithia,Ahmedabad vs DCIT Circle 2 1 1 , Ahmedabad
- Bench: Income Tax Appellate Tribunal - Ahmedabad
- Date: 12 June 2026
- Sections engaged: 148, 148A(b), 148A(d), 149(1)(a), 149(1)(b), 151, 282A, 80G
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Ahmedabad as ITA No. 620/Ahd/2026 for Assessment Year 2019-20. Per the source preview, the assessee challenged the invocation of Section 149(1)(b) on the ground that the alleged escaped income did not exceed Rs. 50,00,000 as required for matters beyond three years from the end of AY 2019-20, and also challenged the reliance by the Assessing Officer on an unsigned approval under Section 151, contending that the absence of a valid digital sanction in violation of Section 282A rendered the reassessment proceedings void. The full substantive outcome and the connection to Section 80G are not further detailed in the source preview available.
10. Shree Giriraj Foundation,Rajkot vs ITO Exemption - 1, Rajkot
- Bench: Income Tax Appellate Tribunal - Rajkot
- Date: 11 June 2026
- Sections engaged: 80G, 80G(5), 80G(5)(ii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Rajkot as ITA No. 748/Rjt/2026, against the order dated 09.03.2026 of the CIT(E), Ahmedabad, denying registration under Section 80G(5). Per the source preview, the assessee had filed an application for approval under Section 80G(5) in Form No. 10AB, and the CIT(E) refused to grant registration on the ground that the trust did not have a valid registration under the prerequisite provision; the full substantive grounds and final outcome are not discernible from the source preview available.
11. Tamanna Education Trust,Mehsana vs The CIT(Exemption), Ahmedabad
- Bench: Income Tax Appellate Tribunal - Ahmedabad
- Date: 11 June 2026
- Sections engaged: 12A, 80G, 80G(5)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeals were filed before the ITAT Ahmedabad as ITA Nos. 935 and 936/AHD/2026 by the same assessee-trust against two separate orders passed by the CIT(E), Ahmedabad, denying registration under Section 12A and approval under Section 80G respectively. Per the source preview, the first appeal (ITA No. 935/AHD/2026) challenged an order dated 08/03/2026 passed by the CIT(E) whereby the application was rejected; the full substantive grounds and final outcome are not discernible from the source preview available.
12. Peoples Protection Trust,Rupavati vs The Commissioner Of Income Tax
- Bench: Income Tax Appellate Tribunal - Rajkot
- Date: 10 June 2026
- Sections engaged: 80G, 80G(5), 80G(5)(ii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal was filed before the ITAT Rajkot as ITA No. 639/Rjt/2025, against an order dated 19.09.2025 of the CIT(E), Ahmedabad, rejecting the assessee's application filed in Form No. 10AB for approval under Section 80G(5)(ii). Per the source preview, the assessee's grounds of appeal contend that the CIT(E) failed to appreciate that the appellant fulfils all substantive conditions prescribed under Section 80G(5)(ii), including the charitable nature of activities, proper accounts, and genuineness of objectives, and that the rejection order is contrary to CBDT Circulars. The final outcome is not discernible from the source preview available.
Patterns across these 12 rulings
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Concentration of Section 80G(5) approval-denial disputes. The majority of cases in this compilation — including those involving Shree Giriraj Foundation, Peoples Protection Trust, Rotary Club of Rajkot Midtown, Shri Mirambika Trust, and Tamanna Education Trust — involve trusts or institutions appealing to ITAT against orders of the CIT(Exemption) denying approval or registration under Section 80G(5). This suggests a sustained volume of first-level rejection decisions being challenged before the tribunal during this period.
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Form No. 10AB as the procedural gateway. Multiple cases (Peoples Protection Trust, Shree Giriraj Foundation, Rotary Club of Rajkot Midtown) specifically reference applications filed in Form No. 10AB, the form prescribed for registration and approval under the amended charitable institution registration framework. Rejection of the Form 10AB application by the CIT(E) is the common trigger for these ITAT appeals.
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Joint Section 12A/12AB and Section 80G proceedings. Several cases — including Chokshi Natvarlal Vachhracharitable, Tamanna Education Trust, and Shri Mirambika Trust — engage both Section 12A (or 12AB) and Section 80G simultaneously, reflecting the structural linkage between trust registration and donor-deduction approval under the post-2021 amended framework.
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Prerequisite registration as a denial ground. The Shree Giriraj Foundation preview explicitly records that the CIT(E) refused Section 80G(5) approval on the ground that the trust did not have a valid registration under the prerequisite provision, indicating that sequencing of registrations (Section 12A/12AB before Section 80G) is a recurring compliance issue across the corpus.
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Mixed docket: registration denials alongside assessment and reassessment disputes. While the dominant theme is Section 80G approval denial, the compilation also includes cases involving donor-level deduction disputes (Arun Pratap Singh), corporate reassessment proceedings (Asian Paints Ltd, Mahesh Upendra Majithia), and a trust property sale civil suit (Essa Ahmed Sait), demonstrating that Section 80G surfaces across a wide range of proceeding types beyond pure registration matters.
How to use this compilation
This compilation is a structured research index, not a digest of decided outcomes. All 12 source records carry the outcome status "Outcome not specified in source," meaning the dispositive orders — whether the ITAT allowed, dismissed, or remanded the appeals — are not fully captured in the previews available to this database at the time of publication. Researchers should treat the entries above as pointers to the underlying judgments and must retrieve and read the full text of each order from indiankanoon.org, the official ITAT e-filing portal, or the relevant High Court's judgment portal before drawing any conclusion about the outcome or the ratio.
Before placing reliance on any ruling listed here, researchers should verify: (a) whether the order has been subsequently stayed, appealed, or reversed by a higher forum; (b) whether any CBDT circular, instruction, or notification has been issued that affects the statutory provision in question; and (c) whether the facts of the matter under research are materially similar to those in the indexed case, given that section 80G disputes are highly fact-specific, particularly on issues of charitable purpose, proportion of religious activity, and procedural compliance with registration requirements.
This compilation will be updated as additional outcome data becomes available in the TaxNoticeAI corpus. Researchers tracking a specific case listed here are advised to set up a docket alert on the relevant tribunal or court portal to receive notifications of subsequent orders in the same matter.
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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