DR. ARCOT LAKSHMANAN SWAMY MEGHANATHAN MUDALIAR TRUST,CHENNAI vs. ITO, EXEMPTIONS WARD-3, CHENNAI

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ITA 687/CHNY/2026Status: DisposedITAT Chennai07 August 2026AY 2022-234 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the registration under Section 12AB was granted for AY 2022-23, the assessee is entitled to claim exemption under Section 11. The order of the CIT(A) was set aside.

What were the facts?

The assessee claimed exemption under Sections 11 & 12. The AO denied this as the assessee's registration under Section 12AB was not substantiated for AY 2022-23. The assessee had received provisional registration and filed for regular registration, which was granted later.

What were the issues?

Whether the assessee is eligible for exemption under Sections 11 & 12 when registration under Section 12AB was granted retrospectively for the assessment year.

Which sections of the Income-tax Act were involved?

Section 11,Section 12,Section 12AB

AI-generated summary — verify with the full judgment below

Before: SHRI SS VISWANETHRA RAVI & SHRI GAGAN GOYAL

Hearing: 04.08.2026

आयकरअपीलीयअिधकरण, ’ए’ �ायपीठ,चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ीयस यस िव�ने� रिव, �ाियक सद� एवं�ी गगन गोयल, लेखा सद�के सम� BEFORE SHRI SS VISWANETHRA RAVI, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No. 687/Chny/2026 िनधा�रणवष�/Assessment Year: 2022-23 Dr. Arcot Lakshmanan Swamy Vs. The Income Tax Officer, Meghanathan Mudaliar Trust, Exemption Ward -3, Sri Vaibhav Apartments, Chennai. Plot No. 4834, 2nd Floor, AB-42 New No-12, 6th Main Road, Chennai – 600 040. [PAN: AACTD-1511-B] (अपीलाथ�/Appellant) (��थ�/Respondent) अपीलाथ�कीओरसे/ Appellant by : Ms. S. Vidhya, CA ��थ�कीओरसे/Respondentby Ms. Anshu Sharawat, Addl.CIT : सुनवाईकीतारीख/Date of hearing : 04.08.2026 घोषणाकीतारीख /Date ofPronouncement 07.08.2026 : आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appealfiled by the assesseeis directed against the order dated 28.01.2026 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2022-23.

2 ITA No.687/Chny/2026 2. At the outset, it is noted that the AO denied the claim of the assessee u/s. 11 & 12 of the Act for not substantiating the validity of registration u/s. 12AB of the Act for AY 2022-23, which was confirmed by the ld.CIT(A).

3.

The ld.AR, Ms. S. Vidhya, CA, submits that the assessee received provisional registration in Form-10AC for AYs 2021-22 to 2023-24 on 27.05.2021 and filed Form-10A on 22.04.2024 for obtaining registration for five years. She submits that the competent authority is expected to pass order on or before 31.03.2022, but however, no order received even after 31.03.2022. She submits as a matter of precaution, the assessee filed again Form 10AB on 02.05.2022 and the ld.CIT(A) rejected the said application vide order dated 04.11.2022. Meanwhile, the competent authority granted registration vide order dated 30.05.2022 for AYs 2022-23 to 2026-27 and she argued in view of the same the assessee is entitled to claim benefit u/s. 11 & 12 of the Act. She prayed to set aside the order of the ld.CIT(A) and direct the AO to allow the claim of exemption u/s. 11 & 12 of the Act.

3 ITA No.687/Chny/2026 4. The ld.DR, Ms. Anshu Sharawat, Addl.CIT, did not dispute the facts narrated by the ld.AR and reported no objection in directing the AO to allow claim of exemption, as claimed by the assessee.

5.

Having heard both the parties, we note that the assessee filed Form 10A on 22.04.2021 which is at page no.5 of the paper book, wherein no dispute with reference to non-passing of order within specified time i.e. 31.03.2022. Further, as stated by the ld.AR with abundant caution the assessee filed Form 10AB again on 05.05.2022 which is at page no.8 of the paper book, wherein the competent authority rejected the same vide its order dated 04.11.2022 by recording reasons that the assessee failed to fulfil the statutory requirements inspite of affording reasonable opportunity vide para 7 of the said order, which is from page no.9 to 11 of the paper book. As matter stood thus, we find the competent authority granted registration on 30.05.2022 which is at page no.14 of the paper book for AYs 2022- 23 to 2026-27 in terms of the application filed on 22.04.2021. Therefore, we find force in the arguments of the ld.AR that the assessee is entitled to claim exemption u/s. 11 of the Act for the year under consideration in view of granting registration dated 30.05.2022 in

4 ITA No.687/Chny/2026 pursuance of application dated 22.04.2021. Thus, order of the ld.CIT(A) is not justified and it is set aside. In view of the discussion made here in above, since the registration granted to assessee we direct the AO to allow exemption esteemed u/s. 11 of the Act. Thus, grounds raised by the assessee are allowed.

6.

In the result, appeal filed by the assessee is allowed. Order pronounced on 07thAugust, 2026 at Chennai. Sd/- Sd/- (यसयसिव�ने�रिव) (गगन गोयल) (GAGAN GOYAL) (SS VISWANETHRA RAVI) लेखा सद�य/Accountant Member �याियकसद�य/ Judicial Member

Chennai, Dated: 07.08.2026 JPV आदेशकी�ितिलिपअ�ेिषत/Copy to: 1. अपीलाथ�/Appellant, 2.��थ�/ Respondent, 3. आयकरआयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय�ितिनिध/DR & 5. गाड�फाईल/GF

PRASAN Digitally signed by PRASANNA NA VANI VANI JETTY Date: 2026.08.10 JETTY 15:48:30 +05'30'

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