AMMA ILLAM TRUST,CHIDAMBARAM vs. CIT EXEMPTIONS, CHENNAI

ITA 2924/CHNY/2026Status: DisposedITAT Chennai05 October 20266 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the assessee had been granted 80G approval in 2015 and renewed in 2022. The assessee's contention that religious clauses were deleted from the Trust Deed on 04.08.2015, and that the current objects are charitable, required proper examination. The Tribunal found merit in the assessee's submission that the impugned order did not clearly identify the specific clause of the Trust Deed or the particular activity considered religious. The Tribunal also noted the assessee's claim of filing an online response on 16.03.2026, which was allegedly not considered by the CIT(E). Considering these points, the Tribunal set aside the impugned order and restored the matter to the CIT(E) for fresh adjudication. The CIT(E) was directed to provide an effective opportunity of hearing, specifically identify any religious clauses or activities, verify the online response, and pass a fresh speaking order. The earlier approval did not preclude fresh examination, but the assessee's contention of no change in objects/activities was a material fact. No opinion was expressed on the merits of the eligibility.

What were the facts?

The assessee, Amma Illam Trust, a public charitable trust, filed an appeal against the order of the Commissioner of Income Tax (Exemptions) [CIT(E)], Chennai. The CIT(E) rejected the assessee's application for renewal/continuation of approval under Section 80G of the Income Tax Act, 1961. The rejection was primarily based on the ground that the trust's objects were both charitable and religious. The assessee had previously obtained 80G approval in 2015, which was renewed/revalidated in 2022. The assessee argued that religious clauses were deleted from its Trust Deed in 2015 and that the CIT(E) failed to consider its response filed online and did not specify the religious objects or activities.

What were the issues?

1. Whether the objects of the assessee-trust are exclusively charitable, or do they include religious objects, thereby disentitling it from 80G approval under Section 80G(5) of the Act? Assessee's contentions: The assessee argued that its principal object is the preservation of cows and supply of milk to old-age homes and orphanages, which is charitable. It contended that any religious clauses in the Trust Deed were deleted by an amendment on 04.08.2015, and the current objects are purely charitable. The assessee also argued that the Department had examined its objects while granting approval in 2015 and revalidating it in 2022. Furthermore, the assessee claimed that the CIT(E) erroneously recorded that no reply was filed, whereas an online response was submitted on 16.03.2026, which was not considered. The assessee requested the matter be restored to the CIT(E) for fresh adjudication. Revenue's contentions: The Revenue, through the ld. DR, relied upon the impugned order passed by the CIT(E).

Which sections of the Income-tax Act were involved?

Section 80G(5),Section 80G,Section 12A,Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: GAGAN GOYAL & SHRI MANU KUMAR GIRI

Hearing: 22.09.2026

PER MANU KUMAR GIRI, JM:

This appeal filed by the assessee-trust is directed against the order passed by the ld. Commissioner of Income Tax (Exemptions), Chennai [hereinafter referred to as “the CIT(E)”] u/s. 80G(5) of the Income Tax Act, 1961 [“the Act”], whereby the application filed by the assessee seeking renewal/continuation of approval u/s. 80G of the Act was rejected.

2.

Brief facts of the case are that the assessee, Amma Illam Trust, is a public charitable trust constit

The order continues below.

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