VANITA SAMAJ,MUMBAI vs. JURISDICTION EXEM WARD 2(4), MUMBAI, MUMBAI

ITA 8116/MUM/2025Status: DisposedITAT Mumbai10 September 2026AY 2017-1829 pages
AI SummaryAllowed

What were the facts?

The assessee, a charitable trust, had its exemption under Section 11 denied by the Assessing Officer and confirmed by the CIT(A) due to alleged commercial activities and issues with Form 10. The denial was based on the proviso to Section 2(15) and Section 13(8) of the Income Tax Act.

What did the Tribunal hold?

The Tribunal held that the assessee was entitled to exemption under Section 11, particularly for accumulation of income under Section 11(2). It found that the subsequent conduct of the assessee corroborated the bona fide character of the accumulation, and inconsistencies in Form 10 were not fatal.

What were the issues?

Whether the assessee's activities constituted business, thereby attracting the proviso to Section 2(15) and disentitling it from Section 11 exemption, and whether the conditions for accumulation of income under Section 11(2) were met.

Which sections of the Income-tax Act were involved?

Section 11,Section 2(15),Section 13(8),Section 11(1)(a),Section 11(2),Section 11(3),Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI MAKARAND VASANT MAHADEOKAR

For Appellant: Shri Anil Sathe, Ld. A.R
For Respondent: Shri Nishant Samaiya, Ld. CIT D.R. a/w, Shri Bal Krishna Yadav, Ld. Sr. D.R
Hearing: 28.07.2026Pronounced: 10.09.2026

PER: MAKARAND VASANT MAHADEOKAR, AM

These three appeals by the assessee are directed against three separate orders, all dated 12.09.2025, passed by the learned Addl./JCIT(A)-2, Chennai [hereinafter referred to as "the CIT(A)"], under section 250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the assessment years 2013-14, 2016-17 and 2017-

18.

The impugned appellate orders arise from assessments completed under section 143(3) of the Act by the Income Tax Officer, Exemption W

The order continues below.

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