CONSORTIUM OF ACCREDITED HEALTHCARE ORGANIZATION,SOUTH DELHI vs. CIT (EXEMPTION), NEW DELHI

ITA 4967/DEL/2026Status: DisposedITAT Delhi09 September 2026AY 2026-2711 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(E) was not justified in denying registration under Section 12A solely on the basis of potential commercial activities or the intention to carry them out. The denial of registration under Section 80G was consequential to the denial under Section 12A.

What were the facts?

The assessee's applications for registration under Section 12A(1)(ac)(ii) and Section 80G(5)(ii) of the Income Tax Act were rejected by the CIT(E). The rejection was primarily based on the CIT(E)'s view that the assessee's activities, particularly those related to sponsorship fees, were commercial in nature and did not qualify as charitable.

What were the issues?

Whether the CIT(E) has the power to deny registration under Section 12A on the ground of commercial receipts or the intention to carry out commercial activities, and if the denial of 80G registration is contingent on 12A registration.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii),Section 80G(5)(ii),Section 2(15),Section 12AB,Section 11(4A),Section 13(8)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI

Before: SHRI ANUBHAV SHARMA

Pronounced: 09.09.2026

PER AMITABH SHUKLA, AM These two appeals by the assessee are directed against the order of the Ld.

Commissioner of Income Tax(Exemption), New Delhi [hereinafter referred to as ‘ld. CIT(E)] both dated 27.03.2026 passed under section 12A(1)(ac)(ii) and 80G of the Income Tax Act, 1961, for the Assessment Year 2026-27. The word ‘Act’ herein this order would mean Income Ta

The order continues below.

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