ADITYA BIRLA EDUCATION TRUST,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

Per Anikesh Banerjee (JM):

The instant appeal of the assessee filed against the order of the Commissioner of Income-tax (Exemptions), Mumbai [for brevity, ‘Ld. CIT(E)’]
passed under section 12AB of the Income-tax Act, 1961 (in short, ‘the Act) date of order 30/06/2025. 2
Aditya Birla Education Trust

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Aditya Birla Education Trust

GENERAL: The Appellant craves leave to add, alter, amend, withdraw or vary all or any of the above grounds of appeal either before or at the time of hearing of this appeal.”

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Aditya Birla Education Trust

(f) UJAAS which supports menstrual health awareness.
3.1
The trust was formed on dated January 16, 2009. It had obtained certificate u/s. 12AA of the Act on November 11, 2009. The said trust deed was modified in 2013 and the same was approved by the Charity Commissioner on September 07,
2013. Pursuant to the change in the Income Tax Act, the trust applied for re- registration u/s. 12A(1)(ac)(i) on April 22, 2021. The registration in respect thereof was granted for a period of five years up to AY 2026-27 as per order of the DIT dated May 28, 2021. On January 28, 2022, the Trustees of the trust passed a resolution for modification of the trust deed mainly with a view to clearly provide for specific objects relating to medical relief. The activities of medical relief were being carried out hitherto under the omnibus object of general public utility in the original trust deed. The revised trust deed was approved the Charity Commissioner on September 02, 2024. 3.2
In view of the modification of the object clause of the trust deed, the assessee made an application before the Ld. CIT(E) for approval of the modified objects as required u/s. 12A(1)(ac)(v) on December 24, 2024. The Ld. CIT(E) has by order dated June 30, 2025, being the impugned order, rejected the application of the assessee and has held that “grant of registration stands rejected”. Being aggrieved the appeal is filed by the assessee challenging such rejection of grant of registration.
4. The Ld.AR argued and filed five (5) sets of paper books (in short “FPB”), containing pages 1 to 2882 which are kept in record. The Ld. AR submitted that the expenditure incurred by the assessee outside India by way of foreign remittance essentially includes payments to University of Cambridge towards examination fees

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Aditya Birla Education Trust for ABWA students, online training workshops result enquiry fees, etc. It also includes payments to international Baccalaureate organizations also towards exam fees to register ABWA students for official assessments and final exams in the IBDP related programmes. Other relatively smaller payments include payment towards subscriptions, payments to faculties conducting training of educators in India and similar payments. The assessee has, apart from year wise complete details of expenses, clarified time and again to the Ld. CIT(E) in its submission that though the payments are made by way of foreign remittance the same are for the purpose of carrying out educational activities entirely in India. The assessee has no educational or other campus abroad and all its activities are being carried out in India only. In fact, there is not even an allegation of Ld. CIT(E) that the assessee has carried out any of its activities outside India.
5. Further it was submitted that the objects of the trust as mentioned in Original trust deed of 2009 includes, inter alia, Clause 4(ii)(a) the object “To establish, manage, run, control either by themselves or jointly with others including other institutions, educational institutions for the purposes of imparting education and not for the purpose of profit and to support and promote advancement of educational institutional activities in all its branches such as kindergarten, primary, secondary and high school and colleges, both of Indian and international curriculum, leading up to and teaching degree courses in Arts, Science, Commerce,
Law, Management, Engineering, Medicine, Pharmacy, Music, Fine Arts,
Architecture and such other educational subjects and courses as the Trustees may deem fit.

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Aditya Birla Education Trust

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Aditya Birla Education Trust education system with international practices. The extract of the relevant clauses of the National Education Policy, 2020 has been reproduced as under: -
“1.3. A National Curricular and Pedagogical Framework for Early
Childhood Care and Education (NCPFECCE) for children up to the age of 8 will be developed by NCERT in two parts, namely, a sub- framework for 0-3 year-olds, and a sub-framework for 3-8 year- olds, aligned with the above guidelines, the latest research on ECCE, and national and international best practices… (FPB Pg
2824)
…
4.20. In addition to high quality offerings in Indian languages and English, foreign languages, such as Korean, Japanese, Thai, French,
German, Spanish, Portuguese, and Russian, will also be offered at the secondary level, for students to learn about the cultures of the world and to enrich their global knowledge and mobility according to their own interests and aspirations. (FPB Pg 2832)
…
5.15. Teachers will be given continuous opportunities for self- improvement and to learn the latest innovations and advances in their professions. These will be offered in multiple modes, including in the form of local, regional, state, national, and international workshops as well as online teacher development modules.
Platforms (especially online platforms) will be developed so that teachers may share ideas and best practices… (FPB Pg 2839)
…

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Aditya Birla Education Trust

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Aditya Birla Education Trust

…
23.4. To remain relevant in the fast-changing field of educational technology, the NETF will maintain a regular inflow of authentic data from multiple sources including educational technology innovators and practitioners and will engage with a diverse set of researchers to analyze the data. To support the development of a vibrant body of knowledge and practice, the NETF will organize multiple regional and national conferences, workshops, etc. to solicit inputs from national and international educational technology researchers, entrepreneurs, and practitioners. (FPB Pg
2874)”
(Emphasis supplied)
9. The Ld. AR thus, submitted that indeed, the activity of imparting Cambridge and IB courses to students in India is in alignment with the National Education
Policy. Imparting of these courses without payment to foreign institutions is not possible. The allegation of the Ld. CIT(E) in para 4.1 that the assessee is intending to provide activities other than education outside India is misleading and arising out of misreading of clause 7(II)(A)(k). The said clause reads as under:
“To design, organize; manage, conduct and operate whether on its own or in association with other persons and / or organizations including overseas organizations; bodies; universities, educational institutions etc. programs, certifications, competitions including international competitions, workshops, seminars, webinars etc.
including but not limited to education training and development

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Aditya Birla Education Trust to teachers, parents, students, employees of various companies,
Trusts, Societies and other institutions.”
(Emphasis supplied)
10. The Ld.AR submitted that in the above clause, the Ld. CIT(E) has emphasised on the words highlighted above namely, “including but not limited to education”, without reading the earlier portion which refers to programs, certifications, competitions including international competitions, workshops, seminars, webinars etc. in the field of education alone. Even the subsequent portion of the clause essentially refers to training and development of teachers, parents, students, etc.
Also, clause (k) falls within the clause 7(II)(A) which refers to “Educational objects”.
The intention, therefore, is abundantly clear that the activities referred to in clause
(k) are in pursuance of educational activities alone. It is submitted that picking up words de-hors of its context is unjustified and unwarranted. It is a matter of fact that the assessee has not and does not intend to carry out any activities outside
India.
11. The Ld.AR relied on following judgments in support of certain legal propositions as under:
a.
Proposition 1: Application of income 'for the purposes in India' is relevant and not 'expenditure incurred within or outside India'.
CIT(E) v. Ohio University Christ College [2018] 408 ITR 352
(Karnataka HC). In this case, the question before the Hon’ble
Karnataka High Court was as follows:

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Aditya Birla Education Trust

“(1) Whether on the facts and in circumstances of the case, the Tribunal is right in deleting faculty teaching charges to Ohio University towards academic expenses by holding that merely because the payments are made outside India, it cannot be said that the charitable activities were also conducted outside India even when the assessee has applied its income for charitable activities outside India and not within which is an essential condition as set out in section 11 of the Act and the assessee has not been granted such exemption by CBDT vide a special order?”
After considering the factual findings rendered by the Tribunal reproduced in para
4 of the said decision, the Hon’ble High Court held that where teaching services were rendered to assessee educational trust by faculty members of a foreign university and such services were utilized for purposes of trust's objective of imparting education, payment made by trust to foreign university for faculty teaching charges falls u/s. 11. Gem and Jewellery Export Promotion Council v. ITO [1999] 68
ITD 95 (Mumbai - Trib). The headnotes of the above decision reads as under:
“The requirement under section 11 is for application of income for charitable purposes in India and its does

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Aditya Birla Education Trust not restrict the application of income within the territory of India. The charitable purpose for which the income should be applied for claiming exemption under section 11(1)(a) should be in India. In this case, the trade delegation had been sent abroad for the benefit of the entire trade in India. The exports were made from India and the purpose for sending the delegation was to increase the possibilities of exports out of India. Since the assessee had applied the income for charitable purposes in India, the mere fact that the expenditure had been incurred out of India, did not disqualify the expenditure from exemption under section 11(1)(a).”

ITO(E) v. J N Tata Endowment for Higher Education of Indians
[2024] 166 taxmann.com 126 (Mumbai - Trib.) held that Disbursal of loan scholarships to students in India for study overseas was application of income for charitable purposes in India, and, thus, would qualify for exemption under section 11. b.
Proposition 2: Incurring expenditure outside India is 'no bar' for denying approval/registration of modified objects of the assessee Trust.
Critical Art and Media Practices v. DIT(E) [2015] 153 ITD
664 (Mumbai Tribunal) held that If activities of a trust are found to be charitable and property is held wholly and 13
Aditya Birla Education Trust exclusively under trust for charitable and religious purposes, then such a trust cannot be denied registration merely because its activities are extended outside India c.
Proposition 3: Application of income outside India, can at worst, result in disentitling the assessee to claim exemption u/s. 11 of the Act to that extent, but it does not disentitle the assessee from getting approval/registration u/s. 12AB of the Act in respect of assessee’s modified objects.

Dedhia Music Foundation v. CIT (E) [2025] 173 taxmann.com 394
(Mumbai - Trib.) held that Application of income of a charitable trust or institution outside India for carrying out its objects would not fall under any categories of 'specified violation' as mentioned in Explanation to section 12AB(4) and, thus, Commissioner
(Exemption) could not deny registration under section 12AB on said ground.
12. Assessee’s submissions as regards “Marwari” community
The Ld. AR argued that the trust deed dated September 07, 2013, which was subject matter of approval in 2021, provides in its object, inter alia, in clause 6(ii) which is reproduced as below:-
“To pay or utilize the balance of such interest dividends and income of the Trust
Fund (hereinafter called "the net income of the Trust Fund" and in the discretion of the Trustees the corpus of the Trust Fund or any part of the corpus) for all or any one or more of the following charitable purposes in such shares and proportions and in such manner in all respects as the Trustees shall in their absolute discretion

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Aditya Birla Education Trust think fit whilst giving appropriate preference to deserving cases of Hindi Speaking students and/or students from Marwari community and otherwise without reference to caste, creed or religion…”.
13. This object has been reiterated in clause 7(iii) of the 2022 Trust Deed which reads as follows:
“Provided however that the Trustees in their absolute discretion may give appropriate preference to deserving cases of Hindi
Speaking students and / or students from Marwari community in the educational institutions established, conducted, controlled, managed and run by the Trust and otherwise carry out its objectives without reference to caste, creed or religion.”
14. This clause talks merely about preference to deserving cases. It is therefore clear that the objects of the trust are not restricted only to Marwari community. In any case Marwari is not a religious community but primarily an ethnolinguistic/regional group. Besides, the preference is to “Hindi Speaking students and/or students from Marwari community”. Hindi speaking students could be from any community. This further reinforces that the objects of the trust of are not restricted to providing benefits to any particular community. Perusal of the data regarding the students to whom scholarships have been granted during academic year 2023-24 annexed in FPB Pg 2339 shows that not more than 2
students out of 17 who got scholarship belong to Marwari community. Just data itself is a testimony that the activities of the trust are not restricted to particular community.

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Christianity, Buddhism. Having regard to the above, application of section 13(1)(b) by the Ld. CIT(E) is grossly misplaced. It may not be out of place to mention that in the notice issued by the Ld. CIT(E) on dated 13/06/2025, FPB Pg 2172, a reference is made to Parsi and Irani Zoroastrians community in para 2 thereof. This indicates a possibility of the Ld. CIT(E) being coloured by some other case handled by him where Zoroastrianism is indeed a religion, but Marwari is not.

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ii. The above decision of the Hon’ble Gujarat High Court was affirmed by the Hon’ble Supreme Court in CIT v. Ahmedabad Rana Caste
Association [1983] 140 ITR 1

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Aditya Birla Education Trust iii. CIT v. Dawoodi Bohara Jamat [2014] 364 ITR 31 (SC). The relevant extract of the decision is reproduced as under: -
“49. In the present case, the objects of the respondent- trust are based on religious tenets under Quran according to religious faith of Islam. We have already noticed that the perusal of the objects and purposes of the respondent-trust would clearly demonstrate that the activities of the trust though both charitable and religious are not exclusively meant for a particular religious community. The objects, as explained in the preceding paragraphs, do not channel the benefits to any community if not the Dawoodi Bohra Community and thus, would not fall under the provisions of Section 13(1)(b) of the Act.
50. In that view of the matter, we are of the considered opinion that the respondent-trust is a charitable and religious trust which does not benefit any specific religious community and therefore, it cannot be held that Section 13(1)(b) of the Act would be attracted to the respondent-trust and thereby, it would be eligible to claim exemption under Section 11 of the Act.”

iv. Human Welfare Foundation v. DCIT(E) [2025] 174 taxmann.com
650 (Delhi - Trib.) (LPB Pg 22 - 50). The relevant extract of the decision is reproduced as under: -

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Aditya Birla Education Trust

“33. In view of the above discussion and by respectfully following the judgments of the Hon'ble Supreme Court and also looking to the facts that assessee society is providing education, medical facility, relief to poor as defined in section 2(15) of the Act which has not been doubted by the Ld. CIT(E) who merely for the reason that major beneficiaries are from a particular religious community has cancelled the registration, which is contrary to the facts of the present case as discussed above. The assessee society never intended to restrict the benefits to a particular religious community and the beneficiaries includes all the sections of the society irrespective of their casts and creed and, therefore, the action of the Ld. CIT(E) in withdrawing registration granted u/s 12A vide order dated 29.05.2009 w.e.f. AY
2018-19 and further registration granted in 12A(1)(ac)
(i) of the Act w.e.f. AY 2022-23 is not in accordance with law. Therefore, the order of the Ld. CIT(E) cancelling the registrations is set aside and registrations granted to the assessee earlier u/s 12A and later vide registration dated 23.09.2021 u/s 12A(1)(ac)(i) of the Act are restored. In the result, grounds of appeal Nos. 2 to 22 taken by the assessee are allowed.”

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Aditya Birla Education Trust b. Proposition 2: Violation of s. 13(1)(b) cannot be the basis for denial of approval/registration u/s. 12AB of the assessee's modified objects.

Gohilwad Vankar Samaj Seva Trust v. CIT [2025] 173
taxmann.com 263 (Ahmedabad - Trib.). Held that “………………..
7. In view of the findings recorded by the Tribunal, supported by decision of this Court in case of Commissioner of Income-tax
(Exemptions) v. Bayath
Kutchhi
Dasha
Oswal
Jain
Mahajan
Trust (2017) 8 IRT-OL 493 (GUJ)/[2016] 74 taxmann.com 199/243
Taxman 60 (Gujarat) that the objects of the trust are not holly for the benefit of a particular religious community, but are largely charitable in character for general public at large and for the purpose of granting registration under 12A of the Act, the provision of section 13(1)(b) cannot be referred to. Section 13(1)(b) is to be applied while granting exemption to the trust. In view above finding, we do not find any question of law much less any substantial question of law arises for consideration."
5. The above judgments will hold good to a Trust created before 01-04-2021. Since the assessee has to first cross the hurdle of being eligible to exemption under section 11 by obtaining a certificate of registration under section 12A of the Act. Having crossed this hurdle then after the provisions of Section 13(1)(b) will get attracted whether the trust suspended for the benefit of 22
Aditya Birla Education Trust particular community, when the trust having mixed objects in it. Therefore, respectfully following the above judicial precedents, the grounds raised by the assessee is hereby allowed. The matter is restored to the file of Ld. CIT
(Exemption) with a direction to grant Final Registration u/s. 12AB of the Act, after giving due opportunity of hearing to the assessee and in accordance with law.”

c. Proposition 3: Since the application was for approval/registration of assessee's modified objects, looking into s. 13(1)(b) compliance which in turn is linked with the entitlement of exemption u/s. 11, the same is beyond ld. CIT(E)'s juri iction, especially when the assessee enjoys a valid and subsisting registration u/s. 12AB of the Act.
CIT(E) v. Jamiatul Banaat Tankaria [2024] 168 taxmann.com 35
(Gujarat HC).
“7. In view of the findings recorded by the Tribunal, supported by decision of this Court in case of Commissioner of Income-tax (Exemptions) v. Bayath
Kutchhi Dasha Oswal Jain Mahajan Trust (2017) 8 IRT- OL 493 (GUJ)/[2016]
74 taxmann.com 199/243 Taxman 60 (Gujarat) that the objects of the trust are not wholly for the benefit of a particular religious community, but are largely charitable in character for general public at large and for the purpose of granting registration under 12A of the Act, the provision of section 13 (1)
(b) cannot be referred to. Section 13(1) (b) is to be applied while granting exemption to the trust. In view of above finding, we do not find any question of law much less any substantial question of law arises for consideration.”

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Aditya Birla Education Trust seminars and webinars for the benefit of Schools, colleges, other educational institutions, companies, organizations etc.
Further, it is also seen that the trust intends to apply funds for a particular community or caste
(students from the Marwari community). This is in violation of section 13(1)(b) of the Act and is also defined as specified violation as per clause (d) of Explanation to section 12AB(4) of the Act.
In view of this, a show cause notice was issued to the applicant vide DIN & Notice No.
ITBA/EXM/F/EXM43/2025 -26/1077008067(1) dated 13.06.2025 and explanations were called for regarding the above-mentioned violations. Additionally, information regarding proof of expenses, copy of bank statements etc were called for vide the same notice dated submissionon20.06.2025 on 13.06.2025 in response, the applicant made subr TAX DEPA
25.06.2025. 3.1. The submission made by the applicant Trust is carefully perused. The relevant portion of applicant's reply dated 20.06.2025 with respect to violation of section 11 of the Act is reproduced in summarized as below:
“…………………
2.1.2 At the outset, the Assessee humbly states that it carries on various education programmes through its verticals / units as mentioned above. The said education programmes are carried in India. As such, the charitable activities are confined in India and none of the activities are carried outside India. For instance, Aditya Birla Education Academy ('ABEA') integrates international best practices with practical, school-based applications, ensuring that the educators remain at the forefront of educational innovation. By offering this comprehensive international programme, the Trust empower educators to adapt to global educational standards while addressing the unique needs of their local contexts.
……………….

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Aditya Birla Education Trust

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Aditya Birla Education Trust institutions and development programs for the benefit of companies cannot be categorized as Education in Scholastic sense. In fact, the Hon'ble Supreme Court in the case of Sole Trustee Lok
Shikshana Trust, reported in 101 ITR 234 has clearly laid down that the scope of education within the meaning of section 2(15) is confined to formal education only, and does not extend to any wider connotation. The relevant findings of Hon'ble Supreme Court are as under The word "education" has not been used in that wide and extended sense, according to which every acquisition of further knowledge constitutes education...... What education connotes in that clause is the process of training and developing the knowledge, skill, mind and character of students by normal schooling.
4.2.1 Further, the Hon'ble Supreme Court in the case of M/S New Noble Educational Society vs
The Chief Commissioner Of Income Tax (Civil Appeal No. 3795 OF 2014) has re-affirmed the view that in case of entities claiming exemption on the ground of imparting education, it has to be concerned "solely" with education or Education related activities; as under-
"60. In the light of the above discussion, this court is of the opinion that the interpretation adopted by the judgments in American Hotel (supra) as well as Queens Education Society (supra) as to the meaning of the expression 'solely' are erroneous. The trust or educational institution, which seeks approval or exemption, should solely be concerned with education, or education related activities. If, incidentally, while carrying on those objectives, the trust earns profits, it has to maintain separate books of account. It is only in those circumstances that 'business' income can be permitted- provided, as stated earlier, that the activity is education, or relating to education. The judgment in American Hotel (supra) as well as Queens Education Society (supra) do not state the correct law, and are accordingly overruled."
Thus, these objects of the Trust Deed are clearly in violation of section 2(15) of the Act, which defines the scope of charitable activities, including Education Courts have consistently taken a view that, for the purpose of section 2(15) Educational activities must be restricted to Scholastic education In the case of the applicant Trust, the objects clearly state that its activities will go beyond the boundaries of scholastic education in the form of educational training and 28
Aditya Birla Education Trust development to employees of various companies, Trusts, Societies and other institutions and These activities cannot be regarded as charitable activities under Education, for the reasons discussed above.
Further, the applicant trust ought to have amended the clauses of the objects mentioned above which are in violation of the statutory provisions, as discussed above, however, the applicant has not considered it. The applicant has not presented/submitted any documentary evidence/proof of passing the resolution regarding amendment in trust deed nor has it provided any proof that it has initiated the process for amendment in trust deed/MoA before the competent authority.”
22. We have carefully considered the rival submissions, the paper book filed, and the impugned order of the Ld. CIT(E). The rejection of registration is due to modification of object of the trust deed in object clause 7(II)(A)(k), 7(II)(A)(I) and 7(iii). The Ld. CIT(E) has taken this as gross violation of section 11 & 13 of the Act in result the application for registration is rejected. Here, the following findings emerge:
On Expenditure Outside India:
22.1. The assessee trust is imparting Cambridge and IB curriculum in India, and the foreign remittances are essentially for exam fees, subscriptions, and training of educators. all for the purpose of imparting education within India.
Reliance placed by the Ld. CIT(E) on Section 11(1)(c) of the Act is misplaced, since the assessee claims exemption u/s 11(1)(a) of the Act. The Ld. DR specifically relied on the fact that the assessee paid foreign remittance Rs. 6.5 crore to university outside India which gross violation of the Section 11 of the Act. We note that the assessee promotes advancement of educational institutional activities in all its branches such as kindergarten, primary, secondary and high school and colleges, both of Indian and international curriculum, leading up to and teaching degree

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Aditya Birla Education Trust courses in Arts, Science, Commerce, Law, Management, Engineering, Medicine,
Pharmacy, Music, Fine Arts, Architecture and such other educational subjects which are at large general public utility. We find that the payment to foreign education institution for expenses towards the charitable activities carried out in India cannot be disallowed. If such an interpretation is taken, then, no charitable hospital will be able to import any equipment, machinery or medicines from a foreign country. Considering, the National Education Policy, 2020 (supra) the students should get the knowledge in foreign education befitting for their future development. Jurisprudence Ohio University Christ College (supra), Gem &
Jewellery Export Promotion Council (supra), J.N. Tata Endowment (supra) and Dedhia Music Foundation (supra) clearly establishes that the activities carried out by the assessee are wholly undertaken within India and any collaboration with international institutions is solely to support and promote advancement of education in India and therefore, entering into such collaborations does not constitute a violation of section 11 of the Act. The payments made to overseas institutions are exclusively towards activities in connection with educational and charitable activities carried out in India and therefore, the same do not amount to application of funds outside India. We respectfully follow the orders mentioned above. Accordingly, it does not constitute violation of section 11 of the Act.
On “Marwari” Community Preference:
22.2. The trust deed merely provides discretion to give preference to deserving Hindi-speaking or Marwari students. This does not amount to restriction for the benefit of a particular religious community or caste u/s 13(1)(b). Marwari is not a religion but an ethnolinguistic/regional group, and the data on record shows

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Aditya Birla Education Trust that scholarships and admissions are widely given to students of varied religions and communities. The activities of developmental programs, workshops, seminars, webinars etc. are also an extension of the main activity of ‘education’ or at best activities in the nature of general public utility and cannot be read in isolation thereof. The Hon’ble Apex Court in Dawoodi Bohra Jamat (supra) and Ahmedabad
Rana Caste Association (supra) has clarified that advancement of benefit to a section of public does not fall foul of section 13(1)(b). Respectfully, following the order of the Hon’ble Apex Court we find that the denial of registration on this ground is legally untenable.
On Scope of Educational Activities:
22.3. The ld. CIT(E) respectfully relied on the order of New Noble
Educational Society (SC). We respectfully follow the said order which is distinguishable. As that ruling was under section 10(23C) of the Act which requires activity solely of education. Under section 11, charitable purposes include education and also general public utility. Training, workshops, and development programmes for teachers, parents, and even employees in mental health awareness, menstrual health, etc., are incidental and in alignment with National
Education Policy, 2020. Hence, these cannot be a ground for denial of registration.
At the stage of considering application for modification of objects u/s 12A(1)(ac)(v), the Ld. CIT(E) is only required to examine whether the amended objects are charitable. Detailed examination of application of income u/s 11 or violation u/s 13
is beyond the scope of such proceedings. Courts have consistently held in Critical
Art and Media Practices (supra) and Jamiatul Banaat Tankaria (supra) that even if 31
Aditya Birla Education Trust certain applications of income are questioned, that would affect exemption in assessment and not registration.
24. In view of the above discussion, we hold that the rejection of the assessee’s application for modification of objects and the consequential denial of registration u/s 12AB is unjustified and bad in law. The impugned order of the Ld.
CIT(E) is hereby set aside. The Ld. CIT(E) is directed to grant approval to the modification of the objects and continue the registration u/s 12AB of the Act, subject to verification of procedural compliance.
25. In the result, the appeal of the assessee bearing ITA No. 4474/Mum/2025
is allowed.
Order pronounced in the open court on 19th day of September 2025. (VIKRAM SINGH YADAV)
JUDICIAL MEMBER
Mumbai, िदनांक/Dated: 19/09/2025
Pavanan

Copy of the Order forwarded to:

BY ORDER,
////

(Asstt.