UTTAR BHARTIYA KSHTRIYA VIKASH PARISHAD,GANDHIDHAM V. THE CIT(EXEMPTION), AHMEDABAD

ITA 299/RJT/2025

AI Insights

The case involves six appeals filed by various charitable trusts against the orders of the Commissioner of Income Tax (Exemption), which had rejected their applications for approval under section 80G(5) of the Income Tax Act, 1961, due to delays in filing Form No. 10AB. The Tribunal considered the procedural requirements and the impact of multiple CBDT circulars that extended deadlines for filing such applications. The Tribunal noted that the delays were not deliberate and were caused by the complexities of the new procedural requirements and changes in the law. Consequently, the Tribunal decided to set aside the CIT(E)'s orders and remand the cases for a decision on the merits.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 847133 (ITAT-RAJKOT)
• Duration Of Justice: 10 month(s) 11 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-03-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Rajkot
• Assessment Year: misc
• Appeal Filed On: 14-05-2025
• Other Referred Cases: N J Charitable Foundation vs CIT(Exemption), Ahmedabad, Shri Shardagram Aumni Education & Charitable Trust, G. C. Foundation, Vananchal Kelavani Trust
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SANJAY PUNGALIA
• Assessee Lawyers: VIMAL DESAI
• Keywords: Condonation of delay; Set aside; Opportunity of being heard; Charitable institution; Procedural lapse
• Section: 11; 12; 10; 80G

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND DR. DINESH MOHAN SINHA, JUDICIAL MEMBER Sl. Nos . आयकर अपील सं/ ITA No(s) िनधाŊरण वषŊ/ Assessment Year(s) Appeal(s) by : अपीलाथȸ / Assessee(s) बनाम/vs. Ĥ×यथȸ/ Respondent(s) 1. 297/Rjt/2025 NA Shree Saibaba Charitable Trust, C/o Sarda & Sarda(CA), Sakar 1st Floor, Dr. Radha- Krishnan Road Opp. Rajkumar College, Rajkot-360001. PAN: AAITS8576R The Commissioner of Income Tax(Exemption) Ahmedabad 2. 298/Rjt/2025 NA Shri Ganga Maiya Seva Samiti Charitable Trust, C/o Sarda & Sarda(CA), Sakar 1st Floor, Dr. Radha- Krishnan Road Opp. Rajkumar College, Rajkot-360001. PAN: AAKTS5107N The Commissioner of Income Tax(Exemption) Ahmedabad 3. 299/Rjt/2025 NA Uttar Bhartiya Kshtriya Vikas Parishad, C/o Sarda & Sarda(CA), Sakar 1st Floor, Dr. Radha- Krishnan Road Opp. Rajkumar College, Rajkot-360001. PAN: AAATU4299B The Commissioner of Income Tax(Exemption) Ahmedabad 4. 300/Rjt/2025 NA Late Shri Naranbha Karmanbha Gadhavi Charitable Trust, C/o Sarda & Sarda(CA), Sakar 1st Floor, Dr. Radha- Krishnan Road Opp. Rajkumar College, Rajkot-360001. PAN: AABTL2954R The Commissioner of Income Tax(Exemption) Ahmedabad Printed from counselvise.com Page | 2 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts 5. 301/Rjt/2025 NA Shrimati Anaridevi Bansilal Goyal Charitable Trust, C/o Sarda & Sarda(CA), Sakar 1st Floor, Dr. Radha- Krishnan Road Opp. Rajkumar College, Rajkot-360001. PAN: AAMTS4016N The Commissioner of Income Tax(Exemption) Ahmedabad 6. 302/Rjt/2025 NA Young Mens Christian Association, C/o Sarda & Sarda(CA), Sakar 1st Floor, Dr. Radha- Krishnan Road Opp. Rajkumar College, Rajkot-360001. PAN: AAATY0175G The Commissioner of Income Tax(Exemption) Ahmedabad Assessee by : Shri Vimal Desai, AR Respondent by : Shri Sanjay Pungalia, CIT. DR Date of Hearing : 06/01/2026 Date of Pronouncement : 25/03/2026 ORDER Per Bench Captioned six appeals filed by the different assessee’s, are directed against the separate orders passed by the Learned Commissioner of Income Tax (Exemption) [in short ‘Ld.CIT(E)’], wherein the Ld.CIT(E) has rejected the application of the assessee in Form no.10AB for approval u/s.80G(5) of the Act, stating that assessee has made the delay in filing application, before him/her, and as the Ld.CIT(E), does not have power to condone the delay in filing Form No.10AB, u/s.80G5(iii) of the Act. Therefore, the Ld.CIT(E) rejected the assessee’s application in Form Printed from counselvise.com Page | 3 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts No.10AB, u/s.80G5(iii) of the Act. Therefore, these different assessees- trust, are in appeal before this Tribunal. 2. Since the issue involved in these six appeals are common and identical, therefore, a consolidated order is being passed for the sake of convenience and brevity. The facts as well as grounds of appeal narrated in ITA No.299/Rjt/2025, in the case of Uttar Bhartiya Kshtriya Vikas Parishad, have been taken into consideration for deciding these appeals en-masse. 3. The grounds of appeal raised by the assessee in ITA No.299/Rjt/2025 in the case of Uttar Bhartiya Kshtriya Vikas Parishad, (lead case) are as follows: “1. The order passed under clause (ii)(b)(B) of second proviso to section 80G(5) of the Act is bad in law. 2. The learned CIT(Exemption) has erred in law as well as on facts in rejecting the application for registration u/s.80G(5) under clause(iii) of its first proviso by considering it as non-maintainable. 4. The facts of the case, which can be stated quite shortly are as follows. The assessee filed application for approval of the trust/institution/fund under clause (iii) of first proviso to sub-section (5) of section 80G of the I.T. Act. 1961, before learned CIT (Exemption). After receipt of the application, the learned CIT( E) observed that the procedure for an approval of an application made under clause (ii) or clause (ii) or sub-clause (B) of clause (iv) under the first proviso to sub-section (5) of section 80G of the I.T. Act, 1961 is governed by the second proviso to sub-section (5) of section 80G of the Act. Further, Rule 11AA(1) of the Income Tax Rules prescribes the different forms to be filed for making application under various clauses of first proviso to sub-section (5) of section 80G of the I.T. Act, 1961, for approval of a trust/institution/fund and Rule 11AA(2) of the Income Tax Rules lists the documents which shall be attached or submitted with the application made in Form No. 10AB. Since the applicant/assessee Printed from counselvise.com Page | 4 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts has filed the application in Form No. 10AB, under clause (iii) of first proviso to sub-section (5) of section 80G of the Act, and noted that it is essential to analyze the provisions of section 80G(5)(iii) of the Act, as it stands from 01.04.2021, which stipulates as under: \"(5) This section applies to donations to any institution or fund referred to in sub- clause (iv) of clause (a) of sub-section (2) only if it is established in India for a charitable purpose and if it fulfils the following conditions, namely Provided that the institution or fund referred to in clause (vi) shall make an application in the prescribed form and manner to the Principal Commissioner or Commissioner, for grant of approval- (iii) where the institution or fund has been provisionally approved, at least six months prior to expiry of the period of the provisional approval or within six months of commencement of its activities, whichever is earlier: \"[or]......” The word \"Date of Commencement of activity has not been defined in Income Tax Act, 1961. However, Hon'ble ITAT-Surat Bench in the case of N J Charitable Foundation vs CIT(Exemption), Ahmedabad in ITA No.783/SRT/2023 under which while allowing the appeal of the applicant has held that 'activities are to be considered as commenced when the donation received is utilized for the charitable activities. The relevant portion of the said judgement is re-produced as under: \"The Ld. AR for the assessee further submits that activities of the assessee-trust actually started on 27.09.2022 when the assessee-trust admitted students for its imparting activities of computer education in furtherance of object of assessee mere taking donation in students in financial year 2021-22 and giving donation in next financial year 2022-23 is in real sense is not the activities. Ultimate activities are to be considered in the hand of recipients for donation from assessee would be when they utilized such donation for their charitable activities. We find that order of Ld CIT(E) that there is no dispute that assessee has given donation to Ram Mandir Charitable Trust on 31.03.2022. The Ld CIT(E) made basis of this donation as a charitable activities and considered the application of assessee-trust beyond the statutory period of six months from commencement of charitable activities. Before us, Ld AR for the assessee vehemently argued that assessee-trust was allowed provisional registration, which is followed up to assessment year 2024-25 and that the assessee-trust Printed from counselvise.com Page | 5 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts was under bona fide belief that they have applied for regular approval well within time limit from the commencement of their activities, which is started from 27.09.2022” 5. The ld.CIT(E ) noticed that in the present case, the applicant has obtained provisional approval under Form 10AC, therefore the provision of clause (iv) of first proviso to sub-section (5) of section 80G of the Income Tax Act-1961, which have been amended from time to are tabulated, as under for ready reference from the date since the said prevision first introduced under Income Tax Act, 1961: Sr.No. From To Provision of Clause(iv) of first proviso to sub-section (5) of section 80G of the Act 1 01.04 2021 30.09.2023 (v) in any other case, at least one month prior to commencement of the previous year relevant to the assessment year from which the said approval is sought 2 01.10.2023 30.09.2024 (iv) in any other case, where activities of the institution or fund have- (A) not commenced at least one month prior to the commencement of the previous year relevant to the assessment year which the said approval is sought (B) commenced and where no income or part thereof of the said institution or fund has been excluded from the total income on account of applicability of sub-clause (iv) or sub-clause (v) or sub-clause (vi) or sub-clause (via) of clause (230) of section 10 or section 11 or section 12 for any previous year ending on or before the date of such application, at any time after the commencement of such activities Printed from counselvise.com Page | 6 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts 3 01.10.2024 Till date (iv) [***] where activities of the institution or fund have (A) not commenced, of least one month prior to the commencement of the previous year relevant to the assessment year from which the said approval is sought, (B) commenced[***]at any time after the commencement of such activities 6. The ld.CIT( E), on plain reading of the above provision, noted that it is clear that application filed under clause (iv) of first proviso to sub-section (5) of section 80G of the I.T. Act, 1961 deals with the cases where the activities of assessee have not commenced. Further, prior making an application under clause(iii), applicant has to filed an application in Form 10A under clause(iv) (for obtaining provisional approval) which is supposed to be filed at least one month prior to the commencement of the previous year relevant to the assessment year from which the said approval is sought. In the present case assessee does not fulfill these conditions. Also in these cases assessee has to regularize provisional approval by filing an application under clause(iii) of first proviso to sub-section (5) of section 80G of the I.T. Act, 1961, within 6 months from the date of commencement of activities. This aspect has been clarified in the conditions while granting registration/approval Form 10AC as under: “C. The institution or fund shall apply for approval within 6 months of commencement of the activities at least 6 months prior to the expiry of period of provisional approval, whichever is earlier” 7. The ld.CIT (E ) noted that considering the difficulties faced by the assessee, the CBDT-New Delhi on multiple occasions has extended the Printed from counselvise.com Page | 7 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts time limit in filing the application in Form 10AB under clause(iii) of first proviso to sub-section (5) of section 80G, as under: Sr.No. Circular no. Relaxation provided for filing application u/s 10AB under section 80G(5)(iii) 1 Circular No 12/2021 dated 25 June 2021 Extended up to 31 August 2021 2 Circular No 16/2021 dated 29th August 2021 Extended up to 31 March 2022 3 Circular No. 8/2022 31 March 2022 Extended up to 30th September 2022 4 Circular No 6/2023 dated 24th May 2023 The date was not extended so far as filing of form 10AB under section 80G(5)(iii) of Income Tax Act 1961 is concerned 5 Circular No. 7/2024 dated 25th April 2024 Extended up to 30th June 2024 \"The said circular also covers the earlier rejected application u/s 80G on the ground of \"delay in filing within due date and \"wrong section\" 8. However, the assessee in this case has failed to avail the benefit of Circular No. 7/2024 dated 25th April 2024, wherein the due date in filing an application under form 10AB has been extended to 30.06.2024 and has now preferred an application for regularization of provisional approval. Further, the time limits prescribed under Income Tax Act-1961 are mandatory and the Commissioner of Income Tax has no power to condone the delay in filing application in Form No. 10AB. Such powers rest with CBDT only. 9. In reference to the application filed by the applicant in FORM 10AB (with above details), the applicant was requested to submit certain details/documents vide notice dated 05.12.2024. In response to the said notice the applicant vide its reply dated 02.01.2025 has submitted certain details. On perusal of such details/documents it is observed that the present Printed from counselvise.com Page | 8 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts application has been filed beyond the time allowed under current statue. Accordingly, a show cause notice was issued to the applicant on 12.02.2025, the relevant part of which reproduced hereunder: \"Please refer to the online application in FORM 10AB by you and the subsequent questionnaires issued to you, in the aforesaid notice/letter certain details/information/clarifications were sought for and in response to the same, you have submitted certain details. As the present application has been filed under clause (iii) of first proviso 80G(5) of the Act, the exiting provision of the said section is reproduced as under “Provided that the institution or fund referred to in clause (vi) shall make an application in the prescribed form and manner to the Principal Commissioner or Commissioner, for grant of approval- (i)where the institution or fund is approved under clause (vi) (as if stood immediately before its amendment by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2000) within three months from the 1st day of April, 2021 (ii) where the institution or fund is approved and the period of such approval is due to expire, at least six months prior to expiry of the said period (iii)where the institution or fund has been provisionally approved, at least six months prior to expiry of the period of the provisional approval or within six months of commencement of its activities, whichever is earlier (iv) where activities of the institution or find have (A) not commenced, at least one month prior to the commencement of the previous year relevant to the assessment year from which the said approval is sought (B) commenced at any time after the commencement of such activities 6,8,9 are amended w.e.f 1.10.2024. 2. On perusal of details/documents submitted by you, is observed that your Trust is found registered on 19.10.2005 and it is also observed that at para 2 of your own reply, you have stated that the date of commencement of activity is 03.10.2005 However, you have obtained provisional approval under Form 10AC on 23.06.2022 i.e from AY 2023-24. 2.1 Hence, as your activities has already been commenced, present application under section 8OG(5)(iii) of the Act (re-produced above) is found to be delayed as you should have obtained provisional certificate one month prior to the commencement of the previous year relevant to the assessment year from which the said approval is sought and should have applied under clause) as above within 5 month from the date of commencement of activities. Further, you have also failed to avail the benefit of circular no. 7 of 2024 issued by CBDT, dated 25.04.2024, Printed from counselvise.com Page | 9 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts whereas time up to 30.06.2024 was allowed the Form 10AB. Therefore the present application filed by you is delayed 2.2 Also, this office has no power to condone the delay so far your present application filed in Form 10AB under section 80G(5)(iii) of the Act is concerned and the above application is liable to rejected 3. In this regard, you are requested to show cause as to why your application fled in Form 10AB under clause(iii) of first proviso to sub section (5) of Section 80G should not be rejected and also your provisional registration should not be cancelled for the reasons discussed as the above para 2. 4. Further, you are requested to note that in case of non-compliance part compliance of said notice the matter will be decided on the basis of facto/material available on record. Please note that this is a final opportunity and no requests for adjournment will be entertained. 5. However, it may be noted that you can file application under clause(iv) (B) of proviso below section 80G (5) of income Tax Act 1961 as per amendment made w.e,f. 1.10.2024. 10. In response to the above show-cause notice, the applicant on 19.02.2025 has submitted its reply. The assessee has accepted that the application filed by it in this case is delayed and requested for condonation of delay in filing Form 10AB. Also, the applicant has relied on various decisions of ITAT, where delay in fling of Form 10AB has been condoned by Hon'ble ITATs. 11. However, ld.CIT(E ) rejected the above contention of the assessee and observed that the applicant vide its own reply dated 02.01.2026, had stated that the date of commencement of activity in its case is 03.10.2005. The assessee accepted that the application filed by it in this case is delayed and requested for condonation of delay in filing Form 10AB. As has been already pointed out that the time limits prescribed in section 80G(5) of the Act are mandatory and the Commissioner of Income Tax has no power to condone the delay in filing application in Form No 10AB. Such powers rest with CBDT only. Also, assessee in this case has failed to avail the benefit of Circular No. 7/2024 dated 25th April 2024.The applicant has also relied on various decisions of ITAT, where delay in fling of Form 10AB has been Printed from counselvise.com Page | 10 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts condoned by Hon'ble ITATs. However, these cases have not been accepted by the department on merit. Also, there is no order of Hon'ble ITAT condoning the delay in this case. In view of the above discussion, it was held by ld.CIT( E) that the present application in Form No. 10AB has not been filed within the time limit prescribed therein and therefore the same is rejected as non-maintainable without going into the merits and the provisional approval issued in Form 10AC also stands cancelled. 12. Aggrieved by the order of the Ld.CIT(E), the assessee is in appeal before us. 13. Learned Counsel for the assessee, argued that the assessee- trust was incorporated on 19.10.2005. The application to grant the provisional registration was filed by the assessee on 13.08.2024. The provisional approval was granted to the assessee on 23.06.2022. After granting provisional approval on 23.06.2022, the assessee must have applied for registration under section 80G(5) (iii) of the Act , however, the assessee did not apply for registration. The Ld. Counsel also submitted in the CBDT Circular No.7/2024 dated 25.04.2024, an opportunity was given to the assessee to file the application for approval under section 80G(5) (iii), however, assessee did not avail this opportunity. The assessee also did not avail the opportunity given by the government with effect from 1st October 2024. The approval for registration u/s.80G expired on 23.12.2022, however, the assessee applied on 13.08.2024. Therefore, the assessee filed the application before the Ld.CIT(E) after expiry of 44 days, (which is mentioned in the CBDT Circular No/7/2024) and therefore, assessee is in appeal before this Tribunal. The Ld. Counsel for the assessee also submitted that this Tribunal has power to condone the delay and therefore, the delay in making application in Form No.12AB u/s.80G(iii) of the Act may be Printed from counselvise.com Page | 11 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts condoned by this Tribunal and direction may be given to the Ld.CIT(E) to grant the approval u/s.80G(5)(iii) of the Act, in accordance with the law. 14. On the other hand, the Ld. CIT(DR) for the Revenue submitted that the assessee has not filed the required application on or before the time limit fixed by the Act, or the time limit extended by the CBDT vide Circular No.7/2024 dated 25.04.2024. Besides, under clause (iii) of proviso to clause (ix) below section 80G(5)(iii) of the Income Tax Act 1961, the amendment was made by the Government with effect of 01.10.2024, however, the assessee did not avail this opportunity also. In this circumstances, these appeals filed by the different assessees should be dismissed. 15. Learned DR further stated that this Tribunal should direct the assessee to file fresh application before the Ld.CIT(E) and these appeals maybe dismissed. That is, there should not be any direction be given by this Tribunal to the Ld.CIT(E) by restoring these appeals to the file of the learned CIT (Exemption), except the direction to the assessee to the effect that assessee may file fresh application before the Ld. CIT(E) and the Ld.CIT(E) may decide the application in accordance with law. Therefore, these appeals, which contain similar identical issue should be dismissed, at the Tribunal level. 16. We have heard, both the parties and carefully gone through the submission put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the fact of the case including the findings of the ld CIT(E) and other materials brought on record. We note that assessee is a trust registered with the office of the Charity Commissioner with effect from 19.10.2005 and it is carrying on charitable activities as per the objects contained in the trust deed. The assessee trust was granted registration u/s. 12A(1)(ac)(i) of the Act vide Printed from counselvise.com Page | 12 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts order dated 24.09.2021.4. The assessee trust also granted provisional registration under clause (iv) of the first proviso to section 80G(5) of the Act vide order dated 23.06.2022.Subsequently, the assessee trust applied for final registration under clause (iii) of the first proviso to section 80G(5) of the Act vide application dated 13.08.2024. Thereafter, the ld. CIT (exemption), Ahmedabad issued a show cause notice requiring the assessee to explain why the said application for final registration/approval should not be rejected on the ground that it was filed beyond the time limit prescribed under CBDT Circular No. 7 of 2024 dated 25.04.2024, which allowed filing of Form No. 10AB up to 30.06.2024. In response to the show cause notice, the assessee trust has accepted that the application filed is delayed and it is unintentional and requested to condone the delay. However, the CIT(exemption), Ahmedabad vide order dated 05.03.2025, rejected the application on a contention that the CIT (Exemption) does not have the power to condone the delay in filing Form No. 10AB and that such power vests exclusively with the CBDT. Accordingly, the application was rejected as non-maintainable without adjudication on merits. 17. We find that the delay was neither deliberate nor intentional. The same occurred as the trustee is not well conversant with the newly introduced procedural requirements for obtaining final registration. Hence, the delay has occurred because of procedural requirements and frequent changes in the law and issues of several circulars by CBDT on this issue which constitutes a bona fide and unintentional procedural lapse that should not defeat substantive justice. The reliance is placed on the following decisions wherein the Hon'ble ITAT condone the delay of the application made for approval u/s 80G(5) of the Act and remitted matter back to file of the CIT(Exemption) for adjudicating the matter on merits: (i) Rajkot ITAT in the case of Shri Shardagram Aumni Education & Charitable Trust (ITA No.175/Rjt/2024 decision dated 28.03.2025). Printed from counselvise.com Page | 13 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts (ii) Rajkot ITAT in the case of G. C. Foundation (ITA No.266/Rjt/2025 decision dated 22.10.2025). (iii) Surat ITAT in the case of Vananchal Kelavani Trust (ITA No.728/Rjt/2023 decision dated 09.01.2024). 18. When substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserves to be preferred. Where no negligence or inaction is imputed to an appellant it can be sufficient cause and liberal construction be adopted and delay should be condoned. Therefore, we condone the delay in case of all the assessees and restore these appeals back to the file of the ld.CIT(E), for fresh adjudication, as per the provisions of the Act. Therefore, we deem it fit and proper to set aside the order of the ld. CIT(E) and remit the matter back to the file of the ld. CIT(E) to adjudicate the issue afresh on merits. 19. Hence, for the reasons given above, we are of the view that the order of the CIT(E) on this issue requires to be set aside and the issue needs to be looked into afresh by the ld.CIT(E). We hold and direct accordingly. The ld.CIT(E) will afford opportunity of being heard to the these assessees before deciding the issue. All these assessees will also be at liberty to let in further evidence to substantiate their case. For statistical purpose, all the appeals of these assessees are treated as allowed. 20. Since we have adjudicated the issue by taking the lead case in ITA No.299/Rjt/2025 and the facts and grounds of appeal in other remaining five appeals are similar and identical and therefore, our observations made in ITA No.299/Rjt/2025, shall apply mutatis mutandis to the aforesaid other appeals of assessees. For the parity of reasons, we allow the abovementioned appeals of other assessees in terms of directions noted in ITA No.299/Rjt/2025. Printed from counselvise.com Page | 14 ITA No.297 to 302/RJT/2025 Uttar Bhartiya Kshtriya Vikas Parishad with other-trusts 21. In the combined result, all appeals of these different assessees, are allowed for statistical purposes. Order is pronounced in the open court on 25/03/2026. S Sd/- Sd/- [ Dr. Dinesh Mohan Sinha ] [ Dr. Arjun Lal Saini ] Æयाियक सदÖय/ Judicial Member लेखा सदÖय/Accountant Member Rajkot Date: 25/03/2026 आदेश की Ůितिलिप अŤेिषत/ Copy of the order forwarded to :  अपीलाथŎ/ The Assessee  ŮȑथŎ/ The Respondent  आयकर आयुƅ/ CIT  आयकर आयुƅ(अपील)/ The CIT(A)  िवभागीय Ůितिनिध, आयकर अपीलीय आिधकरण, राजकोट/ DR, ITAT, RAJKOT  गाडŊ फाईल/ Guard File (True Copy By order, //True Copy// Assistant Registrar/Sr.P.S/PS ITAT, Rajkot Printed from counselvise.com "