AGRAWAL SABHA, RAJNANDGAON,RAJNANDGAON vs. EXEMPTION WARD 2,RAIPUR, RAIPUR

ITA 438/RPR/2026Status: DisposedITAT Raipur13 July 20264 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found merit in the assessee's argument that actual conduct, not just a single bylaw, should determine the society's nature. It was held that the assessee deserved a reasonable opportunity to present its case before the CIT(E).

What were the facts?

The assessee's application for renewal of registration under section 12A(1)(ac)(ii) and registration under section 12AB was rejected by the CIT(E) because the society's bylaws indicated it was established for the benefit of a particular caste, violating Section 13(1)(b). The assessee argued that a single bylaw shouldn't determine the overall nature and that their actual activities benefited the public at large.

What were the issues?

Whether the rejection of registration based on a single bylaw, without considering the assessee's actual activities, was justified. Whether the assessee was established for the benefit of a particular caste or the public at large.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii),Section 12AB,Section 13(1)(b)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY, JM & SHRI AVDHESH KUMAR MISHRA, AM

For Appellant: Shri Bikram Jian CA, Shri Harish Chand Jain, CA, Shri Harsh Jain, CA
Hearing: 03/07/2026

Per Avdhesh Kumar Mishra, AM: This appeal filed by the assessee is directed against the order dated 25.03.2026 of Commissioner of Income Tax (Exemption), [CIT(E)], Bhopal rejecting not only the renewal of registration under section 12A(1)(ac)(ii) of the Income Tax Act, 1961 (‘Act’) but also the registration under section 12AB of the Act.

The order continues below.

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