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ITAT held that the rejection of registration u/s 12A(1)(ac)(iii) and cancellation of provisional registration u/s 12AB of the trust was unsustainable. Applying the governing precedent, the Tribunal found that mere origin from a community platform and beneficiary description as a "Samaj" does not ipso facto render the trust for a particular religious community or caste; a fact-specific inquiry is required into whether the community constitutes a religious denomination and whether activities are exclusionary in practice. The CIT(Exemption) failed to distinguish "caste" from "religious community" and made no categorical findings, notwithstanding financials evidencing public-welfare expenditure. The impugned order was quashed and the matter remitted for fresh, reasoned adjudication.
ITAT held that the rejection of registration u/s 12A(1)(ac)(iii) and cancellation of provisional registration u/s 12AB of the trust was unsustainable. Applying the governing precedent, the Tribunal found that mere origin from a community platform and beneficiary description as a "Samaj" does not ipso facto render the trust for a particular religious community or caste; a fact-specific inquiry is required into whether the community constitutes a religious denomination and whether activities are exclusionary in practice. The CIT(Exemption) failed to distinguish "caste" from "religious community" and made no categorical findings, notwithstanding financials evidencing public-welfare expenditure. The impugned order was quashed and the matter remitted for fresh, reasoned adjudication.
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