LIKEMINDED EDUCATION AND WELFARE SOCIETY ,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION) , MUMBAI

IN THE INCOME-TAX APPELLATE TRIBUNAL “A” BENCH,
MUMBAI
BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER
&
SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER
&
M/s Likeminded
Education and Welfare
Society, 1, Nivan, Plot
No. 96, SV Road, Khar
West, Mumbai - 400 052,
Maharashtra v/s.
बनाम
Commissioner of Income
Tax
(Exemptions), Mumbai, 601, 6th
Floor, Cumballa Hill, MTNL TE
Building,
Peddar
Road,
Dr.
Gopalrao
Deshmukh
Marg,
Cumballa Hill Mumbai - 400051,
Maharashtra
Appellant/अपीलार्थी
..
Respondent/प्रतिवादी

Appellant by :
Shri Jagdish Shetty, AR
Respondent by :
Shri Rajesh Kumar Yadav (CIT-DR)

Date of Hearing
11.06.2025
Date of Pronouncement
16.06.2025

आदेश / O R D E R

PER PRABHASH SHANKAR [A.M.] :- The above captioned appeals have been filed by the assessee Trust against two separate orders as passed by the Learned Commissioner of Income-tax (Exemptions), Mumbai [hereinafter referred to as “CIT(E)”] pertaining to order passed u/s. 12AB/80G of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 20.02.2025. Since the issues involved are interlinked and also the fact that both appeals were heard together, they are being taken up together for adjudication vide this composite order for the sake of brevity.

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(1)
Incorrect Invocation of the provisions of Section 11 of The Income Tax
Act, 1961:
On the basis of facts and circumstances of the case, the Learned
Commissioner of Income Tax (Exemptions), Mumbai [Hereinafter referred to as “CIT(Exemptions)”] erred in confirming rejection of registration citing the violation of Provisions of Section 11 of The Income
Tax Act, 1961 without considering the fact that your appellant has not applied any of its income outside India till date which is adequately and duly supported by documentary evidences submitted to the office of the Lrnd. CIT(Exemptions).
Further, Learned CIT(Exemptions) has erred in invoking the provisions of Section 11(1)(c) of The Income Tax Act, 1961 merely on the ground that the MOA and Rules & Regulations provide for the application of Income outside India thereby misinterpreting the said section without understanding the difference between “Actual Application” outside India and “Providing for Application” of funds outside India.
On the basis of the facts and circumstances of the case, the Learned CIT
(Exemptions) has erred in law and on facts by misinterpreting the provisions of Section 11 of the Income Tax Act, 1961, in as much as the said provisions pertain to the denial of exemption to the extent of actual application of income outside India, and not to the denial of registration under Section 12A of the Act.
(2)
On the basis of facts and the circumstances of the case, the Learned CIT
(Exemptions) erred in failing to appreciate & consider the unforeseen medical circumstances that led to the delay in filing Form 10AB which were explained before the Lrnd. CIT(Exemptions) during the course of proceedings.
(3)
On the basis of the facts and circumstances of the case, the Learned
Commissioner of Income Tax (Exemptions) has erred in failing to appreciate that the appellant is a genuine charitable organization, and that the denial of registration would consequently deprive the appellant of eligible exemptions under the Act, thereby adversely impacting its ability to carry out its objectives of social and public welfare merely on account of some procedural lapse due to unforeseen and uncontrollable circumstances.

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Maharashtra Public Trust Act, 1950 incorporated on 30th of May,
2023.It is claimed that it is incorporated with the main objective of serving the community at large through the conduct of Social and Charitable activities, to facilitate financial assistance and aid to the children belonging to the underprivileged and weaker sections of the society particularly for educational and medical purpose and other social and cultural activities. It had filed for application of Provisional
Registration under Sub Clause (iii) of Clause (ac) of sub-section (1) of Section 12A of the Act, vide Form 10A dated 17th July, 2023 and it was granted provisional registration under Section 12A vide order for Provisional approval in Form 10AC dated 24th July, 2023. 4. The ld.CIT(E) on verification of the application for final approval for registration in Form 10AB found that the application was not complete, and all the documents required to be accompanying the application were not furnished. Hence, a notice was issued to it requesting to furnish the complete set of documents mentioned in Rule
17A(2). After a careful perusal of the submissions made, it was noticed by him from the trust deed/MOA that as per point 3(iii) and 3(vii) of the objects of the trust deed/MoA, that the applicant intended to apply fund outside India which is inviolation of section 11 of the Act. The objects of the trust deed/MOAare reproduced below for reference:

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 3(iii): To obtain affiliation with various universities and institutes, whether in India or abroad.....
 3(vii): To assist deserving students in availing overseas education including provision of overseas travelling expenses, boarding and lodging expenses, fees and other expenses in connection with the overseas education of such students.

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M/s Likeminded Education and Welfare Society of activities, copy of bank statements etc were called for vide the same notice dated 06.02.2025. 4.3
The applicant in response to the delay in filing Form 10AB, the applicant had admitted that the Trust must apply for regular registration at least six months before the expiry of the provisional registration or within six months of commencement of activities, whichever is earlier. The applicant has stated that due to unforeseen medical circumstances of the trustee, it was unable to submit the application within the required timeframe. The applicant has also requested for condonation of delay in filing form 10AB for grant of certificate u/s 12A.
4.4
The ld.CIT( E) further that the due date of filing application on or before 30.06.2024 as per the said circular was an extension provided by the Board to all the Trust/Institution to file/re-file their applications under certain conditions. However, the applicant was not able to show any reasonable cause, for delay or to establish that the applicant trust had genuine hardship in filing of the application within the due date. In absence of a reasonable cause of delay the request of the applicant to condone the delay was not acceptable.
4.5
Regarding the issue of violation of provisions of section 11
of the Act the applicant trust had stated that the trust had neither

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M/s Likeminded Education and Welfare Society engaged in applying any funds outside India nor has received any funds from abroad which can be evidenced from the details of sources of funds and applications of funds submitted alongwith supporting documents. It further stated that it will amend the clauses in the MOA which are in violation of provisions of section 11 of the Act.However, it has neither submitted/presented resolution passed by trust nor submitted any proof that it has applied for amendment in MOA before the MCA.
4.6
Thus, the application for regularization of provisional approval in Form 10AB filed by the assessee was not allowed on the ground of late filing of application and violation of provisions of section 11 of the Act.
5. In the course of hearing before us, the ld.AR has submitted that the assessee is a Public Charitable Society incorporated with the main objective of serving the community at large through the conduct of Social and Charitable activities with the vision to facilitate financial assistance and aid to the children belonging to the underprivileged and weaker sections of the society particularly for educational and medical purpose and other social and cultural activities. After obtaining provisional registration under Section 12A vide Order for Provisional approval in Form 10AC dated 24th July, 2023, it commenced its activities towards the objectives of the Society. Further, it then filed an application for Final registration in accordance with Sub Clause (iii) of P a g e | 7

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Clause (ac) of sub-section (1) of Section 12A in Form 10AB dated 26thAugust, 2024. 5.1 In response to various notices issued by the CIT(E) due compliance was made. Surprisingly, the assessee was in receipt of rejection order dated 20th February 2025 in Form 10AD rejecting the application made for registration under Section 124(1)(ac)(iii) of the Act, citing the following reasons:
“Thus, the application for regularization of provisional approval in Form
10AB filed by the assessee is not allowable on the ground of late filing of application and violation of provisions of section 11 of the Act”.
5.2 It is contented by the ld.AR that evident that the assessee made all the submissions, details and explanations in respect of registration under Section 12A of the Act, within the prescribed due date. The Ld.CIT(E) passed the rejection order without consideration of the details, documents and explanations submitted by the Trust within the prescribed due dates.
5.3 In so far as the reasons for rejection of registration and invoking the provisions of Section 11 of the Act is concerned, it is submitted that the Ld.CIT(E) has erred in rejecting the application for registration under Section 12A of the Act, by invoking the provisions of Section 11 of the Act due to the following reasons:

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M/s Likeminded Education and Welfare Society i.
The assessee has applied its income in India by way of carrying out charitable activities which align with its objectives such as providing educational assistance to the weaker sections of the Society and medical assistance. The said fact is established by way of documentary evidences submitted to the office of the Lrnd. CIT(Exemptions); however, the same have been summarily disregarded while concluding the proceedings ii.
The ld. CIT(Exemptions) has erred in misinterpreting the provisions of Section 11(1)(c) of the Act. It is pertinent to note that the provisions of Section 11(1)(c) of Act focuses on denial of exemption under Section 11 of the Act in case of application of funds outside India and not the denial of registration under Section 12A of The Income Tax Act, 1961. iii.
Further, if there is a clause in the trust deed which provides for activities outside
India, it would not dis-entitle the organization from claiming exemption. The provisions of section 11(1)(c) are attracted only if actual expenditure is incurred outside India. Section 11(1)(c) cannot be invoked only on the ground that the constitutional documents provides for activities outside India.

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M/s Likeminded Education and Welfare Society society is not allowed to apply its fund outside India and such application is not allowed as deduction from its taxable Income. Thus it is proved that your appellant has not committed any violation as per
Section 11(1)(c) of the Tax.
5.6 As regard non-consideration of uncontrollable circumstances leading to procedural delays, it is submitted that due to unforeseen medical circumstances of the applicant trustee an active member of the society),the assessee was unable to submit the application within the required time frame. The said delay was on account of circumstances beyond the control of the Society. As a result, the application was submitted in August 2024. Therefore, by passing the rejection order, it is being penalized on account of unforeseen medical circumstances which are beyond its control. It is requested to consider the circumstances surrounding and condone the delay.
5.7 It is further stated that non-consideration of the explanations submitted by the appellant and issuing an adverse order without giving an opportunity of being heard is against the principle of Natural Justice and shall cause undue hardship to it. The delay in filing of application for registration was on account of genuine medical reasons of the Trustee / President which was beyond its control. Denial of registration based on the above reason shall cause genuine hardship to the assessee.

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7. We have carefully considered all the relevant facts of the case, perused the record, gone through provisions of the Act in this regard alsolegal position on the issues involved. It is an admitted fact that the application for final registration was delayed as pointed out by the P a g e | 12

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M/s Likeminded Education and Welfare Society ld.CIT(E) though it is claimed that the delay was on account of certain medical reasons attributed to the President although the claim is not supported by any evidence brought on record.

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M/s Likeminded Education and Welfare Society facts after detailed analysis of the provisions of the Act and various judicial precedent granted liberty to the assessee to specify the memorandum of the objects and file the application seeking final registration before the competent authority which may be considered in accordance with law. We find it appropriate here to quote relevant paras of the above mentioned order for the sake of brevity as below:
“2. The assessee was granted provisional registration on 01.10.2021 pursuant to filing of application in Form 10AB u/s.12A(1)(ac)(iii) before the Ld.CIT(E). It is submitted that the assessee was formed with following objections:
………….
……………
12. To provide support and other such developmental services to other organisations in India and outside India in the social sector.
2.1. Ld.CIT(E) observed that object clause no.12 of memorandum of association provides support to other such development services to other organisation in India and outside India in the social sector. The Ld.CIT(E) was thus of the opinion that the said object clause, violates section 11 of the Income Tax Act and therefore registration u/s. 12AB cannot be granted since the assessee has not established genuineness of the activities. The Ld.CIT(E) also noted that, the assessee has not established whether this object is in compliance with any other law for the time being in force as are material for the purposes of achieving its objects. The Ld.CIT(E) thus rejected the application seeking registration u/s. 12AB vide impugned order.As a consequences application seeking 80G registration was also denied.
Aggrieved by the orders of the Ld.CIT(E), the assessee is in appeal before this Tribunal.
3. The primary contentions of the Ld.AR was that, the assessee was granted provisional registration in Form 10AC, and therefore the assessee may be granted registration u/s. 12AB of the Act. It is submitted that, subsequent to the provisional registration granted to the assessee activities of the trust/institution commenced and once Ld.CIT(E) is satisfied about activities undertaken by the trust/institution were genuine and in consonance with the aims and objectives of the trust/institution, the denial of registration u/s. 12AB of the Act is bad in law.

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3) Amended process w.e.f. 01.10.2023 where in only organizations who have not started any activity may apply for provisional registration and where the activity is commenced then direct application for five-year registration is permissible.
4.1. In the present facts of the case, the assssee, was incorporated on 28/07/2021
and filed its application under section. Thus, the assessee falls under the new regime of registration process, seeking registration/approval from 01.04.2021 to 30.09.2023, w.e.f. 01.04.2021 under section 12AB of the Act. The key features of registration under the amended scheme from 01.04.2021 to 30.09.2023
under section 12AB are as under:
(i) Concept of provisional registration introduced for charity institutions is applicable to all applying for the first time, irrespective of whether they are new or existing institutions.
(ii) Concept of perpetuity of registration stands withdrawn under the new scheme and provisional registration is valid for a maximum period of 3 years. The provisional registration is subsequently required to be regularized into five years regular registration within six months of commencement of activities or at least 6
months before the expiry of the provisional registration period.
(iii) All the existing trusts or institutions which were registered under section 12A/ 12AA or approved under section 10(23C) and section 80G are mandatorily required to obtain registration under new scheme of registration under section 12AB or to obtain approval under section 10(23C) and section 80G. The registration/approval shall remain valid for a period of five years from 1 April,
2021 i.e. from the AY: 2022-23. (iv) Registration/approval was subject to renewal every 5 years.
4.2. The assessee in the present facts of the case preferred application for the first time post July 2021. Thus, as per section 12AB and Rule 17, the assessee is required to pass through following two stages:
1) Firstly, the application is to be filed in Form 10A for provisional registration.
The assessee in the present facts filed Form 10A r.w. Rule 17, on 06/09/2022. Based on the application made, a provisional registration was issued to the assessee u/s.12AB effective from 01/10/2021. 4.2.1. For seeking Provisional Registration, apart from the documents and information required for filing application under Form 10A, no other information will be sought for granting provisional registration.
The relevant provision of section 12AB is reproduced as under:
(1) The Principal Commissioner or Commissioner, on receipt of an application made under clause (ac) of sub-section (1) of section 12A, shall,

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(a)... (b)...
(c) where the application is made under sub-clause (vi) of the said clause, pass an order in writing provisionally registering the trust or institution for a period of three years from the assessment year from which the registration is sought, 4.2.2. Thus, it is apparent that, upon filing application in Form 10A (for Provisional registration) the concerned Income-tax Authority (CIT or PCIT) has to issue provisional registration certificate without any further verification or examination.
4.3. In the second stage, this provisional registration is required to be converted into regular registration. The application for conversion is to be filed in Form
10AB at least 6 months before the expiry of the provisional registration period or within 6 months of the commencement of its activities, whichever is earlier. For Converting provisional registration into final registration, procedure is identical to what it was prevailing prior to 01.04.2021, under section 12AB(1)(b)(i). That is, the Ld.PCIT/CIT shall call for such documents or information or make such inquiries as he thinks necessary in order to satisfy himself about genuineness of the activities of the trust or institution and the compliances of other laws.The relevant provisions are as under:
(1) The Principal Commissioner or Commissioner, on receipt of an application made under clause (ac) of sub-section (1) of section 12A, shall,-- a) where the application is made under sub-clause (i) of the said clause, pass an order in writing registering the trust or institution for a period of five years; b) where the application is made under sub-clause (ii) or sub-clause (iii) or sub- clause (iv) or sub-clause (v) 66[or item (B) of sub-clause (vi)] of the said clause,-- i) call for such documents or information from the trust or institution or make such inquiries as he thinks necessary in order to satisfy himself about-- a) the genuineness of activities of the trust or institution; and b) the compliance of such requirements of any other law for the time being in force by the trust or institution as are material for the purpose of achieving its objects;(emphasis supplied)
4.3.1. Thus once the Ld.PCIT/CIT is satisfied on above aspects, then registration shall be granted in Form 10AD. In other case the application will stand rejected after granting an opportunity of being heard (as per section 12AB(1)(b)(ii) of the Act). Further, according to Sub-section 4 and 5 of section 12AB inserted by Finance Act, 2022, with effect from 01/04/2022, Ld.PCIT/CIT may cancel registration (after providing reasonable opportunity of being heard) if it is found that, the activities are not genuine or are not carried out in accordance with the objects of trust/institution.At this juncture, we note the fact that provisions of sub sections are applicable to the present assessee based on the date of application filed seeking registration under section 12B of the Act.

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(b) the trust or institution has income from profits and gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in respect of the business which is incidental to the attainment of its objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust for private religious purposes, which does not enure for the benefit of the public; or (d) the trust or institution established for charitable purpose created or established after the commencement of this Act, has applied any part of its income for the benefit of any particular religious community or caste; or (e) any activity being carried out by the trust or institution--
(i) is not genuine; or (ii) is not being carried out in accordance with all or any of the conditions subject to which it was registered; or (f) the trust or institution has not complied with the requirement of any other law, as referred to in item (B) of sub-clause (i) of clause (b) of sub-section (1), and the order, direction or decree, by whatever name called, holding that such non- compliance has occurred, has either not been disputed or has attained finality.
(5) The order under clause (ii) or clause (iii) of sub-section (4), as the case may be, shall be passed before the expiry of a period of six months, calculated from the end of the quarter in which the first notice is issued by the Principal
Commissioner or Commissioner, on or after the 1st day of April, 2022, calling for any document or information, or for making any inquiry, under clause (i) of sub- section (4).
4.3.3. One of the intention of Legislature to introduce sub clause (4) and (5) to the section 12AB is to address the issue related to the process of approval or cancellation or withdrawal thereof.
Clause 3.3(a)(i) of memorandum explaining the provisions in finance bill, 2022 is as under:
"3.3. Reference to the Principal Commissioner or Commissioner (PCIT/CIT) for the cancellation of registration/approval:
a)The following issues related to the process of approval or registration, or cancellation or withdrawal thereof, have been noticed, namely:- i) Registration or approval of non-genuine trusts or institution under automated approval system: First and second provisos to clause (23C) of section 10 of the Act were substituted by new provisos by the Taxation and Other Laws (Relaxation

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M/s Likeminded Education and Welfare Society and Amendment of Certain Provisions) Act, 2020 w.e.f. 01.04.2021. These provisos provided that the application for the approval of any trust or institution under the first regime, shall be made to the juri ictional Principal Commissioner or Commissioner and such Principal Commissioner or Commissioner shall grant approval after examination of the application. Earlier such applications were required to be filed before the prescribed authority. Similarly, provisions of clause
(ac) of sub-section (1) of section 12A provide that application for the trusts or institution under the second regime shall be made to the principal Commissioner or Commissioner. The provisional registrations or provisional approval orre- registrations or approvals in certain cases, under these clauses, are granted in an utomated manner and the respective rules have been amended accordingly. It is essential to ensure that non-genuine trusts or institutions do not get exemption provided by these provisions."
Thus, we do not agree with the argument advanced by the Ld.AR that since provisional registration is granted to the present assessee before u/s.12AB, final registration cannot be denied.
4.4. In the present facts, the assessee's objects include clause 12, which is not in consonance with the main purpose to grant exemption under section 11(1)(a) of the Act for sale of convenience, the relevant portion are excluded as under. It is noted that, the assessee was offered opportunity of being heard, is apparent from the paper book filed before us. However, nothing on record is filed, to demonstrate that, the assessee took necessary steps to amend the objects which is in contravention to section 11(1)(a) of the Act. Admittedly it is not the case that, the assessee has already applied its funds as per object clause 12 of the memorandum.
4.4.1. It is relevant to note that section 11 (1) (a) was on statute from its inception to the provisions of section 11(1)(c ) that reads as under:
Section 11....
(1)....
(a) to (b).....
(c) income derived from the property held under trust--
(i) created on or after the 1st day of April, 1952, for a charitable purpose which tends to promote international welfare in which India is interested, to the extent to which such income is applied to such purposes outside India, and (ii) for charitable or religious purposes, created before the 1st day of April, 1952, to the extent to which such income is applied to such purposes outside India:
Provided that Board, by general or special order, has directed in either case that it shall not be included in the total income of the person in receipt of such income;

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M/s Likeminded Education and Welfare Society assessee trust which would result in expenditure outside India. During the hearing before him, the assessee trust had submitted for amending this object. It may be stated here that the coordinate bench in the case of Sila for Change Foundation v/s CIT(E)(supra) gave liberty to the assessee to specify the memorandum of the objects and file the application seeking final registration before the competent authority which may be considered in accordance with law. Therefore, having considered the facts and circumstances of the present case and the in the light of amended provisions, we deem it appropriate to restore the application for seeking registration under section 12AB of the Act to the file of the ld. CIT(E) for de novo adjudication with a direction to the assessee to file its amended object at the earliest before the ld. CIT(E), which may be considered in accordance with law.

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M/s Likeminded Education and Welfare Society in the case of Narke Green Foundation Charitable Institution
ITA no.1864/Mum/2025 gave following directions:
“5.9 At this juncture we refer to the pragmatic approach advocated by Justice
V.R. Krishna Iyer, wherein he advocated a flexible approach to procedural law, that serve as "handmaid" to justice, and not a hinder it. The Principle of Justice Krishna Iyer emphasised that procedural laws should be tools to facilitate administration of justice various decisions of Hon'ble Supreme Court has emphasised to strike a balance between strict adherence to procedural rules and the need to ensure that justice is not denied due to technicalities.
5.10 We agree with the above preposition observed by Hon'ble Pune Tribunal.
However genuine and bonafide reason stated by the assessee cannot be over looked. Further we also note that, flexible and pragmatic approach to such procedural laws is necessary as against recognising a strict adherence to do which could sometime lead to injustice. Hon'ble Supreme Court in plethora of cases always emphasised that while considering delay, one must first ascertain bonafides of the explanation offered by the party seeking condonation.
Thereafter there must be sufficient cause which is substantianable based on the genuine reasonable explanation.
5.11 While condoning the delay it is crucial to ensure the party seeking condonation provide genuine explanation for the delay. In present facts of the case, we note that, the reason that caused delay is based on a bonafide belief on behalf of the assessee without there being any malafide intention.
6. In our considered opinion assessee must get an opportunity to present its case before the Ld.CIT(E) and to explain the reason that caused the delay. The Ld.CIT(E) shall consider the application of assessee seeking condonation of delay in accordance with law keeping in view to the above principles of natural justice.”
9. Respectfully following the above decision, we deem it appropriate to restore the application for seeking registration under section 12AB of the Act to the file of the learned CIT(E) for de novo adjudication on the delay in submission of relevant application before the ld. CIT(E), which may be considered in accordance with law.
10.ITA No.2648/MUM/2025

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M/s Likeminded Education and Welfare Society aside and the matter is restored to the file of the learned CIT(E) for deciding it afresh. As a result, the grounds raised by the assessee are allowed for statistical purposes.
12. In the result, both appeals by the assessee are allowed for statistical purposes.
Order pronounced in the open court on 16.06.2025. SANDEEP GOSAIN
PRABHASH SHANKAR
(न्यायिक सदस्य /JUDICIAL MEMBER)
(लेखाकार सदस्य/ACCOUNTANT MEMBER)

Place: म ुंबई/Mumbai
ददनाुंक /Date 16.06.2025
Lubhna Shaikh / Steno

आदेश की प्रयियलयि अग्रेयिि/Copy of the Order forwarded to :
1. अपीलार्थी / The Appellant
2. प्रत्यर्थी / The Respondent.
3. आयकर आयुक्त / CIT
4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT,
Mumbai
5. गार्ड फाईल / Guard file.

सत्यावपि प्रवि ////
आदेशानुसार/ BY ORDER,

उि/सहािक िंजीकार (Dy./Asstt.