MATITSSIA FOUNDATION,MADURAI vs. CIT(E), CHENNAI

ITA 2087/CHNY/2026Status: DisposedITAT Chennai29 September 2026AY 2025-269 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that since the CIT(E) had rejected the assessee's applications primarily based on his earlier order concerning the parent association, MADITISSIA, and given that the Tribunal had restored MADITISSIA's applications for de novo consideration, the assessee's claim for registration should also be considered afresh. The Tribunal directed the assessee to participate before the CIT(E) on the date of hearing without fail and submit all relevant documents. The CIT(E) was instructed to pass orders after hearing the assessee in accordance with the law. The appeals were allowed for statistical purposes, implying a remand for fresh consideration by the lower authority. The specific finding on whether the activities were charitable was deferred pending the fresh adjudication.

What were the facts?

The assessee, Maditssia Foundation, filed appeals against the order of the Commissioner of Income Tax (Exemption), Chennai, dated 31.03.2026, which rejected its applications for registration under Section 12AB and approval under Section 80G of the Income Tax Act, 1961. The assessee had previously obtained registration under Section 12A and approval under Section 80G, and later applied for fresh registration under the new regime. The CIT(E) rejected the applications, holding that the assessee's predominant activity of letting out its auditorium and facilities was commercial in nature and not charitable or educational, as defined under Section 2(15). The CIT(E) also noted that the assessee primarily functioned as a facility provider to its parent association, MADITISSIA, whose own application for registration had been denied.

What were the issues?

1. Whether the assessee-Foundation's activities of renting out its auditorium and related facilities constitute charitable purposes as defined under Section 2(15) of the Income Tax Act, 1961, thereby entitling it to registration under Section 12AB and approval under Section 80G. Assessee's Contention: The assessee argued that the CIT(E) erred in rejecting its applications based on the denial of its parent association's (MADITISSIA) application. The assessee highlighted that the Tribunal had previously set aside the order rejecting MADITISSIA's application for de novo consideration. Therefore, the assessee sought a similar opportunity to present its case before the CIT(E) and for its application to be decided after MADITISSIA's application is adjudicated. Revenue's Contention: The Ld. DR opposed the assessee's plea.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G,Section 2(15),Section 12A(1)(ac)(ii),Section 80G(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY. S

Hearing: 04.08.2026Pronounced: 29.09.2026

PER ABY T. VARKEY, JM: These are appeals preferred by the assessee-Foundation against the order passed of the Ld. Commissioner of Income Tax (Exemption), Chennai, dated 31.03.2026 for registration u/s.12AB and approval u/s.80G of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2.

The assessee-Foundation claims to have been formed by trust deed dated 03.03.1993 and was granted registration u/s.12A of the Act on 23.01.1998 and certificate of approval under 80G o

The order continues below.

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