INCOME TAX OFFICER, EXEMPTIONS, MADURAI, MADURAI vs. SRI KRISHNA EDUCATIONAL & CHARITABLE TRUST, ODDANCHATRAM

PDF · subscribers
ITA 891/CHNY/2026Status: DisposedITAT Chennai29 July 2026AY 2013-144 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal found that while the CIT(A) allowed exemption based on a screenshot of Section 12A approval and a prior year's acceptance, there was no detailed verification of the approval's validity and period. However, considering the prior year's acceptance by the Revenue, the CIT(A)'s order was upheld.

What were the facts?

The Revenue appealed against the CIT(A)'s order allowing exemption under Section 11 to the assessee trust. The AO had denied exemption due to non-submission of Section 12A approval and a large cash deposit, while the CIT(A) allowed it based on a screenshot of approval and a prior assessment year's acceptance.

What were the issues?

Whether the CIT(A) was justified in allowing exemption under Section 11 without proper verification of Section 12A approval, and whether the prior year's acceptance by the Revenue impacts the current year's decision.

Which sections of the Income-tax Act were involved?

Section 11,Section 12A

AI-generated summary — verify with the full judgment below

Before: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Respondent: Ms. R. Anita, CIT, Mr. C. Karthik, Advocate
Hearing: 17.06.2026Pronounced: 29.07.2026

आयकर अपीलीय अिधकरण, ’ए’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी इंटूरी रामाराव, लेखा सद� एवं �ी एस.एस. िव�ने� रिव, �ाियक सद� के सम� । Before Shri Inturi Rama Rao, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. No.891/Chny/2026 िनधा�रण वष�/Assessment Year: 2013-14 The Income Tax Officer (E), Vs. Sri Krishna Educational & Madurai, Charitable Trust, 625002. 185/09, Thiruvalluvar Salai, Oddanchatram,Tamil Nadu, 624619. [PAN: AAGTS9962D] (अपीलाथ�/Appellant) (��थ�/Respondent) Department by : Ms. R. Anita, CIT Respondent by : Mr. C. Karthik, Advocate Date of hearing : 17.06.2026 Date of Pronouncement 29.07.2026 : आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the revenue is directed against the order dated 29.12.2025 passed by the ld. Commissioner of Income Tax (Appeals), NFAC, Delhi for the assessment year 2013-14.

2.

The Revenue raised seven grounds of appeal, amongst which the only issue emanating for our consideration is as to whether the ld. CIT(A) is justified in holding that the assessee is entitled to claim exemption under section 11 of the Income-tax Act, 1961 (for short, "the Act") in the

2 I.T.A. No.891/Chny/26

facts and circumstances of the case. At the outset, it is noted that the assessee is a Trust conducting its activities under the name and style of Sri Krishna Educational & Charitable Trust. According to the AO, no return of income was filed and the case of the assessee was re-opened on the belief that income chargeable to tax has escaped assessment in view of the deposit of cash amounting to ₹2,97,74,752. Further, the AO observed that the assessee furnished the acknowledgement of manual filing of the income-tax return along with the details as sought by the AO on 18.02.2022, which are reproduced at page Nos. 2 to 4 of the assessment order. Further, the AO denied the exemption under section 11 of the Act for non-submission of approval under section 12A of the Act by recording his reasons in para Nos. 14 to 16 of the assessment order. Before the ld. CIT(A), it was contended that the assessee got approval under section 12A of the Act and the AO completed the scrutiny assessment for AY 2018-19 by allowing the exemption under section 11 of the Act. We find the said submissions at page No. 28 of the impugned order and, by considering the same, the ld. CIT(A) held that the assessee is entitled to claim exemption under section 11 of the Act.

3.

Before us, the ld. DR, Ms. R. Anita, CIT, contended that the assessee failed to furnish a copy of the approval before the AO and no

3 I.T.A. No.891/Chny/26

return of income was filed. The ld. CIT(A), without verifying the same and bringing nothing on record, allowed the exemption under section 11 of the Act. She prayed to remand the matter to the file of the ld. CIT(A) for his fresh consideration, bringing all facts with reference to the material evidence on record.

4.

Ld. AR, Mr. C. Karthik, Advocate, relied on the order of the ld. CIT(A).

5.

Heard both the parties and perused the relevant records. We note that admittedly no approval was furnished before the AO and a screenshot of the approval was furnished before the ld. CIT(A). We find that the ld. CIT(A), taking into consideration the said submission of the assessee with reference to the screenshot showing approval under section 12A of the Act, and also the assessment related to AY 2018-19, allowed the claim of the assessee. However, we find no discussion whatsoever with reference to the approval under section 12A of the Act, mentioning the date of approval and also the period from which the approval has been granted. Further, we find no details filed before us by the assessee showing the copy of the approval commencing with effect from a particular date. Therefore, we find force in the argument of the ld. DR that the ld. CIT(A), without verifying the same and without bringing the

4 I.T.A. No.891/Chny/26

details of the approval under section 12A granted, allowed exemption under section 11 of the Act. However, as it appears that for AY 2018-19 the respondent Revenue accepted the claim of the assessee and, taking into account the same, we find the order of the ld. CIT(A) justified in holding that the assessee is entitled to claim exemption under section 11 of the Act. Thus, the grounds raised by the Revenue are dismissed.

6.

In the result, the appeal filed by the Revenue is dismissed.

Order pronounced on 29th July, 2026 at Chennai.

Sd/- Sd/- (INTURI RAMA RAO) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated, 29.07.2026 MM/- आदेश की �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant, 2.��थ�/ Respondent, 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR & 5. गाड� फाईल/GF.

MANISH Digitally signed by MANISH MISHRA MISHRA Date: 2026.07.30 12:02:25 +05'30'

More judgments on Section 11

All 7,190 judgments and leading authorities on Section 11 →

Recent GST High Court judgments

Search GST case law →