SANGITA CHARITABLE TRUST,CHENNAI vs. ITO, EXEMPTIONS WARD-3,, CHENNAI
What were the facts?
The assessee, a charitable trust, advanced loans to its trustees. The Assessing Officer (AO) denied the trust's exemption under Section 11 of the Income Tax Act, 1961, for the entire gross receipts, citing violations of Section 13. The CIT(A) upheld the AO's order.
What did the Tribunal hold?
The Tribunal held that violation of Section 13 does not lead to forfeiture of exemption for the entire income. Only the income diverted or applied for the benefit of specified persons is liable to tax.
What were the issues?
Whether denial of exemption under Section 11 for the entire income is justified when there is a violation of Section 13, or only to the extent of the benefit conferred on specified persons.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘B’ BENCH, CHENNAI
Before: SHRI MANU KUMAR GIRI & SHRI S. R. RAGHUNATHA
PER S. R. RAGHUNATHA, AM : The present appeal is filed by the assessee against the order dated 27.01.2026 passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “ld.CIT(A)”), dismissing the appeal filed by the assessee against the assessment order passed by the Income Tax Officer, Exemption Ward – 3,
:-2-: ITA. No.1614 /Chny/2026
Chennai
The order continues below.
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More judgments on Section 11
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- M/S. Development Education & Welfare Trust… vs I.T.O., Ward - 2(3), AlipurduarITA 2367/KOL/2026[2020-2021]Status: Disposed7 Oct 2026AY 2020-2021
- M/S. Development Education & Welfare Trust… vs I.T.O., Ward - 2(3), AlipurduarITA 2366/KOL/2026[2019-2020]Status: Disposed7 Oct 2026AY 2019-2020
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