CSI CHENNAI CHAPTER,CHENNAI vs. CIT EXEMPTIONS, CHENNAI

ITA 2973/CHNY/2026Status: DisposedITAT Chennai29 September 202612 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal considered the sole issue of whether the CIT(Exemption) was justified in rejecting the grant of registration under Section 12AB. The CIT(Exemption) had denied registration primarily because the assessee was deemed a mutual benefit association, benefiting only its members and not the public at large, engaging in commercial activities, and failing to prove the voluntary nature of its receipts or application of funds for charitable purposes. The Tribunal noted that the assessee society was formed under the Societies Registration Act, 1860, and that Section 12D of that Act empowers the society. The judgment does not explicitly state the Tribunal's final decision on the registration or the Section 80G(5) application, nor does it provide the reasoning for its conclusion or the ratio decidendi. The operative directions are not recorded.

What were the facts?

The assessee, CSI CHENNAI CHAPTER, filed an appeal against the order dated 30.03.2026 passed by the Commissioner of Income Tax (Exemption), Chennai. The CIT(E) denied the grant of registration under Section 12AB of the Income Tax Act, 1961. The assessee is a society formed with stated charitable objects, including holding meetings, arranging discourses, encouraging research, and engaging in public education. The assessee applied for registration in Form No. 10AB on 29.09.2025. The CIT(E) sought information, which was provided by the assessee on 31.03.2026. The CIT(E) concluded that the society was formed for the benefit of its members, not the public at large, and operated on the principle of mutuality. It was also concluded that the society received commercial gross receipts, failed to prove the voluntary nature of its income, and had not applied funds for charitable purposes like relief of the poor, education, or medical relief. The application for approval under Section 80G(5) was also denied.

What were the issues?

1. Whether the Commissioner of Income Tax (Exemption) was justified in rejecting the appellant's application for registration under Section 12AB of the Income Tax Act, 1961, based on the conclusion that the society is predominantly for the benefit of its members and not the general public, operates on the principle of mutuality, receives commercial gross receipts, and has not applied funds for charitable purposes as defined under Section 2(15)? (Question of law and mixed fact and law, turning on Section 12AB and Section 2(15) of the Income Tax Act, 1961). Assessee's contentions: The CIT(E) failed to appreciate that the society's objects benefit the public at large. The classification as a mutual benefit association was an error, as the Societies Act prohibits dividend distribution. At the time of registration, only the objects of the society should be considered. Regarding the Section 80G(5) application, a co-ordinate bench had restored the matter to the CIT(E)'s file. Revenue's contentions: The CIT(E) passed a well-reasoned order considering the society's objects, and the order should not be interfered with.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 2(15),Section 80G(5),Section 12D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CHENNAI BENCHES,

Before: SHRI INTURI RAMA RAO & SHRI SS VISWANETHRA RAVI

Pronounced: 29.09.2026

PER INTURI RAMA RAO, ACCOUNTANT MEMBER :

This appeal filed by the Assessee directed against the order passed by learned Commissioner of Income Tax(Exemption), Chennai dated 30.03.2026 denying grant of registration u/s.12AB of the Income Tax Act, 1961. 1 CSI CHENNAI CHAPTER

2.

The Assessee raised the following grounds of appeal : “1.The Commissioner of Income Tax (Exemption) is not justified in rejecting the appellant's application under item (ii) of clause (ac) of sub section (1) of section

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 12AB

All 5,972 judgments and leading authorities on Section 12AB →

Recent GST High Court judgments

Search GST case law →