MANN MEDICITI EDUCATIONAL FOUNDATION,MANN MEDICITI WELLNESS CENTRE PVT LTD. KHAMBRA vs. INCOME TAX OFFICER (EXEMPTION WARD), JALANDHAR

ITA 125/ASR/2025Status: DisposedITAT Amritsar27 May 2026AY 2022-238 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal, noting the assessee's grievance about not being granted a proper hearing and the need for further examination of evidence, remanded the matter back to the CIT (Exemption). The CIT is to provide the assessee one more opportunity to present its case and supporting documents.

What were the facts?

The assessee, a company incorporated in 2021, applied for registration under Section 12A(1)(ac)(iii) to carry out charitable activities. The CIT (Exemption) rejected the application, finding the assessee's home care services to be commercial in nature due to significant surplus generation and lack of evidence of charitable intent.

What were the issues?

Whether the activities of the assessee, providing home care services, are charitable or commercial in nature, and whether adequate opportunity for hearing was provided to the assessee.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii),Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: DR. DIPAK P. RIPOTE & SH. UDAYAN DAS GUPTA

Hearing: 18.03.2026Pronounced: 27.05.2026

Per: Udayan Dasgupta, JM:

This appeal is filed by the assessee against the order of the Ld CIT (E), Chandigarh, dated 16/12/2024, rejecting the application for registration dated 30/06/2024, filed by the assessee in Form 10AB u/s 12A(1)(ac)(iii) of the Income Tax Act 61 ( henceforth the Act ).

2.

The grounds of appeal taken by the assessee in Form 36 are as follows:

“1. That the CIT (Exemption) was not justified in not granting registration u/s 12AA of the Act without appreciating the facts and circumstances of the case. The detailed submissions made have not been appreciated. Assessment Year: 2022-23 2

2.

That the CIT Exemption was not justified in treating the activi

The order continues below.

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