ARSHA VIDYA RESEARCH AND PUBLICATION TRUST,CHENNAI vs. CIT EXEMPTIONS, CHENNAI

ITA 2906/CHNY/2026Status: DisposedITAT Chennai24 September 20264 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(E) erred in rejecting the assessee's application for registration under Section 12AB of the Income Tax Act. The CIT(E) relied on Supreme Court decisions in Sole Trustee, Loka Shikshana Trust and New Noble Educational Society without adequately considering the specific objects and facts of the assessee's case. The Tribunal found that the CIT(E) must examine the objects of the trust when determining approval under Section 12AB, and this examination was absent in the impugned order. Therefore, the Tribunal found merit in the assessee's argument that a fresh examination by the CIT(E) was required. The order of the CIT(E) was set aside, and the matter was remanded to the CIT(E) for fresh examination. Similarly, the issue regarding Section 80G approval was also remanded to the CIT(E) for fresh examination as it was consequential to the Section 12AB issue. The grounds raised by the assessee were allowed for statistical purposes.

What were the facts?

The assessee, Arsha Vidya Research and Publication Trust, filed appeals challenging orders passed by the Commissioner of Income Tax (Exemption), Chennai. The appeals concern the assessment year(s) not explicitly stated but relate to applications for registration under Section 12AB and approval under Section 80G of the Income Tax Act. The CIT(E) rejected the assessee's application for registration under Section 12AB, relying on Supreme Court decisions in Sole Trustee, Loka Shikshana Trust and New Noble Educational Society, without considering the assessee's specific facts and objects. The CIT(E) also rejected the application for approval under Section 80G. The assessee argued that the CIT(E) arbitrarily rejected the applications and prayed for a remand for fresh examination. The revenue supported the CIT(E)'s order. The Tribunal heard both appeals together due to similar issues and facts.

What were the issues?

1. Whether the Commissioner of Income Tax (Exemption) erred in rejecting the assessee's application for registration under Section 12AB of the Income Tax Act, 1961, solely based on Supreme Court decisions without examining the assessee's objects and facts? 2. Whether the Commissioner of Income Tax (Exemption) erred in rejecting the assessee's application for approval under Section 80G(5) of the Income Tax Act, 1961? Assessee's Contentions: - The CIT(E) rejected the Section 12AB application based on Supreme Court decisions without considering the assessee's specific facts and circumstances, arbitrarily holding it could not be processed. - The CIT(E) failed to examine the objects of the trust in determining the approval under Section 12AB. - The issue regarding Section 80G approval is consequential to the Section 12AB issue. - Prayed for remand of both matters to the CIT(E) for fresh examination. Revenue's Contentions: - The revenue vehemently opposed the appeals and supported the order of the CIT(E).

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G(5)

AI-generated summary — verify with the full judgment below

Before: SHRI. INTURI RAMA RAO & BEFORE SHRI S.S. VISWANETHRA RAVI

Hearing: 09.09.2026

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

without taking into account the facts These appeals are filed by the assessee is directed against the order dated 24.03.2026 passed by the Commissioner of Income Tax (Exemption), Chennai.

2.

Since the issues raised in both the appeals are similar based on same identical facts. Upon hearing both the parties and with their

ITA No.2906 & 2907/Chny/2026

consent, we proceed to hear both the app

The order continues below.

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