JINSEVA FOUNDATION,MUMBAI vs. CIT (EXEMPTION), MUMBAI

ITA 3531/MUM/2025Status: DisposedITAT Mumbai29 August 2025AY 2025-2026Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SMT. RENU JAUHRI ( (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the mention of utilizing funds outside India in the MOA does not automatically warrant rejection of registration. It reasoned that such clauses can be interpreted as availing services from foreign counterparts for the benefit of people in India.

What were the facts?

The assessee, Jinseva Foundation, applied for registration under Section 12AB of the Income Tax Act. The CIT(Exemptions) rejected the application, citing that the objects of the foundation allowed for utilization of funds outside India, which was considered a violation of Section 11.

What were the issues?

Whether the objects of a foundation allowing for utilization of funds outside India are grounds for rejection of registration under Section 12AB, and if such clauses can be interpreted differently.

Which sections of the Income-tax Act were involved?

Section 12A,Section 12AB,Section 11,Section 80G

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “F” MUMBAI

Before: MS. KAVITHA RAJAGOPAL & SMT. RENU JAUHRI

For Appellant: Mr. Margav Shukla, Mr. Vivek Perampurna, CIT-DR
Hearing: 21/08/2025

PER RENU JAUHRI, AM

These two appeals by the assessee are directed against two separate order both dated 27.03.2025 passed by the Ld. Commissioner of Income-tax (Exemptions), Mumbai [in short ‘the Ld. CIT(E)’] for assessment year 2025-26 respectively.

2.

The grounds raised by the assessee in ITA No. 3531/Mum/2025 are reproduced as under:

ITA Nos. 3531 & 2 3532/MUM/2025 Jinseva Foundation Jinseva Foundation

Ground - 1 - The Hon. CIT (Exemptions) on the facts and in the The Hon. CIT (Exemptions) on the facts and in the circumsta

The order continues below.

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