Tag Archives: IN THE ITAT CHANDIGARH BENCH

A trust predominantly engaged in cow protection cannot be classified as a religious entity or denied Section 80G approval based on dormant temple clauses or Gita discourses.

By | August 10, 2026

A trust predominantly engaged in cow protection cannot be classified as a religious entity or denied Section 80G approval based on dormant temple clauses or Gita discourses. Issue Whether a trust with dominant objects of cow protection, animal welfare, and ethical value education can be categorized as a “Religious Entity” under Section 12AB due to… Read More »

Providing transportation services on commercial lines to school students does not constitute charitable purpose under section 2(15).

By | August 10, 2026

Providing transportation services on commercial lines to school students does not constitute charitable purpose under section 2(15). Issue Whether an institution providing student transport services on commercial lines against a fee, generating recurring surpluses, is entitled to regular registration under Section 12AB as a charitable entity under Section 2(15) of the Income-tax Act, 1961 /… Read More »

RWA activities confined to members follow doctrine of mutuality and lack public charity under Section 12AB.

By | August 5, 2026

RWA activities confined to members follow doctrine of mutuality and lack public charity under Section 12AB. RWA activities confined to members follow doctrine of mutuality and lack public charity under Section 12AB. Issue Whether a Residents Welfare Association providing maintenance and facility services exclusively to its members operates under the doctrine of mutuality, thereby lacking… Read More »

Rental income applied to charitable objects and reasonable CEO remuneration do not forfeit trust exemption.

By | August 3, 2026

Rental income applied to charitable objects and reasonable CEO remuneration do not forfeit trust exemption. Issue Rental Income & Commercial Activity: Whether a charitable trust forfeits exemption under Sections 11 and 12 when it earns substantial rental income by leasing trust property, where such leasing is empowered by the trust deed and the receipts are… Read More »

Section 12AB registration cannot be denied on unverified statutory breaches, requiring fresh adjudication.

By | July 24, 2026

Section 12AB registration cannot be denied on unverified statutory breaches, requiring fresh adjudication. Issue Whether registration under Section 12AB can be denied to a university based on alleged contraventions of non-tax laws (Haryana Private Universities Act and FCRA) and accounting discrepancies without any adverse finding by the competent regulatory authorities. Whether the CIT(E) can declare… Read More »

Refusal to Condone Delay Unjustified When Assessee Was Incarcerated and Raised Substantial Legal Challenges

By | June 27, 2026

Refusal to Condone Delay Unjustified When Assessee Was Incarcerated and Raised Substantial Legal Challenges Issue Whether the Commissioner (Appeals) was legally justified in dismissing an appeal in limine as time-barred by refusing to condone a delay of 227 days, when the assessee was incarcerated in jail, unable to obtain a digital signature for e-filing, and… Read More »

Application for Section 12AB registration cannot be rejected without recording a reasoned finding on specified violations.

By | June 25, 2026

Application for Section 12AB registration cannot be rejected without recording a reasoned finding on specified violations. Application for Section 12AB registration cannot be rejected without recording a reasoned finding on specified violations. Issue Whether the Commissioner (Exemptions) is justified in rejecting a trust’s application for fresh registration under section 12AB on the grounds that its… Read More »

Assessee blocks uncorroborated search additions, but stock deficits and unproven HUF rents stand.

By | June 22, 2026

Assessee blocks uncorroborated search additions, but stock deficits and unproven HUF rents stand. Issue Whether search-and-seizure-based additions concerning alleged on-money payments, unrecorded loose-paper transactions, protective gross profit adjustments, stock deficiencies, unaccounted purchases/sales, and unverified rental income claims are legally sustainable under the provisions of the Income-tax Act? Facts On-money & Third-Party Sheets (I & II):… Read More »

Section 80G Approval Remanded for Fresh Examination After Tribunal Restored Assessee’s Section 12AB Charitable Registration

By | June 11, 2026

Section 80G Approval Remanded for Fresh Examination After Tribunal Restored Assessee’s Section 12AB Charitable Registration Issue Whether a competent authority’s rejection of an application for approval under Section 80G is sustainable when the sole ground for rejection—the denial of registration under Section 12AB—has been overturned and restored in favor of the assessee by the Income… Read More »