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50. (2025) 177 taxmann.com 590 (Ahd Trib)
Akshat Education and Charitable Trust vs. CIT
A.Y.: N.A. Date of Order: 19.08.2025
Section: 80G
Application for final approval under section 80G(5)(iv)(B) cannot be denied on the ground that the applicant had claimed exemption under section 11 / 10(23C) in the past.
Amendment in section 80G(5)(iv) made by Finance Act 2024 is clarificatory in nature and applies retrospectively.
FACTS
The assessee was a registered public charitable trust under the Bombay Public Trusts Act, 1950, engaged in imparting education. The Trust had commenced its activities in 2014 upon receiving school opening permission and had been claiming exemption under section 11 and section 10(23C) in earlier years. However, it had never obtained approval under section 80G(5). For the first time, the Trust was granted provisional approval under section 80G(5) for the period from 22.06.2022 to A.Y. 2025-26. Pursuant to this, the appellant moved an application in Form 10AB on 06.02.2024 seeking final approval under section 80G(5).
CIT
