SRI SHIVAGANGA YOGA CENTRE,ABHISTAVARA VINAYAKA TEMPLE FRONT vs. INCOME TAX OFFICER, WARD-1, HUBLI

ITA 2117/BANG/2026Status: DisposedITAT Bangalore23 September 2026AY 2020-216 pages
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What were the facts?

The assessee, Sri Shivaganga Yoga Centre, filed an appeal against the order dated 26.03.2026 passed by the learned Additional/Joint Commissioner of Income Tax (Appeals) for Assessment Year 2020-21. The assessee, a public charitable trust, initially filed a return which was treated as defective by the CPC, Bangalore, leading to a demand of Rs. 3,00,650/-. A corrected return was filed after obtaining a revised Form 10B, and the CPC processed it disallowing exemption under Section 11. The learned Addl./Joint CIT(A) upheld this denial, citing that the new registration under Section 12A was dated 24.09.2021 and applicable only from AY 2022-23 to 2026-27, thus disallowing application of income (Rs. 4,15,287/-) and accumulation (Rs. 1,18,968/-). The assessee contended it had a valid registration under Section 12A dated 14.11.2007, which was inadvertently not produced before the CIT(A).

What did the Tribunal hold?

The Tribunal noted that the registration certificate considered by the learned Addl./Joint CIT(A) was issued under Section 12A(1)(ac)(i), which is applicable only when the assessee already held a registration under Section 12A. The Tribunal observed that the learned CIT(A) failed to appreciate this aspect and did not call for the earlier certificate granting registration under Section 12A. Therefore, considering the facts and circumstances, the Tribunal deemed it appropriate to grant the assessee one more opportunity to furnish the earlier registration certificate issued under Section 12A of the Act. The matter was restored to the file of the Jurisdictional Assessing Officer for de novo adjudication after considering the earlier registration certificate. The impugned order was set aside, and the grounds raised by the assessee were allowed for statistical purposes. No issue was expressly left undecided.

What were the issues?

1. Whether the denial of exemption under Section 11 of the Income Tax Act, 1961, for Assessment Year 2020-21 is justified in law and on facts, given the assessee's claim of having a valid registration under Section 12A of the Act dated 14.11.2007. (Mixed question of law and fact, turns on Section 11 and Section 12A). Assessee's contentions: The assessee argued that it possessed a valid registration under Section 12A dated 14.11.2007, which remained valid for the year under consideration and was never cancelled. The fresh registration obtained under the new regime (Section 12A(1)(ac)(i)) was for subsequent years. The failure to produce the original 14.11.2007 registration certificate before the CIT(A) was an inadvertent omission. Revenue's contentions: The learned Departmental Representative relied upon the orders passed by the lower authorities.

Which sections of the Income-tax Act were involved?

Section 11,Section 12A,Section 12A(1)(ac)(i),Section 143(1),Section 154,Section 139(8A),Section 250,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SANDEEP SINGH KARHAIL

PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER:

The assessee has filed a present appeal against the impugned order dated 26.03.2026 passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Additional/Joint Commissioner of Income Tax

ITA 2117/BANG/2026 SRI SHIVAGANGA YOGA CENTRE

(Appeals), Madurai [“learned Addl./Joint CIT(A)”], for the assessment year 2

The order continues below.

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