2025 (10) TMI 364 - SCH - Income Tax

Registration under section 12AA and claim for 80G(5) exemption: High Court's approval upheld, SLP dismissed

Registration as a charitable institution under the income tax regime was held to logically support grant of donor tax exemption; the High Court directed ... Rejecting the application for grant of benefit of exemption u/s 80G (5) - assessee’s application u/s 12AA was granted and is continuing in operation - HC held [2024 (12) TMI 321 - CHHATTISGARH HIGH COURT] no hesitation to hold that since the assessee stands registered as charitable institution u/s 12AA the only corollary is, its application u/s 80G (5) also deserves to be allowed which the ITAT has rightly noticed to be the correct legal position and directed the CIT(E) to grant approval to the assessee u/s 80G (5). Question of law is answered in favour of the assessee. HELD THAT:- In the peculiar facts and circumstances of the case, we are not inclined to interfere with the well-reasoned order passed by the High Court. Hence, the Special Leave Petition is dismissed. 'Delay condoned.' The Court heard the matter and, on the stated reasoning, declined to disturb the High Court's determination. Relying on the record and the 'peculiar facts and circumstances of the case,' the Court observed it was 'not inclined to interfere with the well-reasoned order passed by the High Court.' Consequently, the 'Special Leave Petition is dismissed.' Any 'pending application(s), if any, shall stand disposed of.' The decision reflects deference to the High Court's factual and legal evaluation and denotes finality as to the contested relief.