CENTRE FOR E-GOVERNANCE ,BANGALORE vs. DCIT, EXEMPTION, CIRCLE-1 , BANGALORE

ITA 936/BANG/2025Status: DisposedITAT Bangalore31 December 2025AY 2021-22Bench: SHRI WASEEM AHMED (Accountant Member), SHRI SOUNDARARAJAN K (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessee is a state-owned entity and its activities are for the advancement of general public utility. The Tribunal further held that the interest income earned on EMD is also for charitable purposes. Therefore, the assessee is eligible for exemption under Section 11.

What were the facts?

The assessee, Centre for E-Governance, a society established by the Karnataka Government, claimed exemption under Section 11 for its e-governance activities. The assessee received various fees and earned interest on earnest money deposits. The Assessing Officer (AO) denied the exemption, holding that the activities were commercial in nature and fell under the proviso to Section 2(15).

What were the issues?

Whether the activities of the assessee, a government-established society, are charitable in nature and eligible for exemption under Section 11, considering the proviso to Section 2(15) and the nature of its receipts.

Which sections of the Income-tax Act were involved?

Section 11,Section 2(15),Section 13(8)

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Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K

For Appellant: Shri S Parthasarthi, Advocate
For Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Hearing: 18.12.2025Pronounced: 31.12.2025

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is an appeal filed by the assessee against the order of the NFAC, Delhi vide order dated 13/02/2025 in DIN No. ITBA/NFAC/S/250/2024- 25/1073253398(1) for the assessment year 2021-22. 2. The assessee has raised as many as 17 Grounds of appeal which are interconnected to each other. Therefore, we, for the sake of brevity and convenience, are not inclined to reproduce the same here.

3.

The interconnected issue raised by the assessee is that the ld. CIT-A erred in denying the exemption claimed under section 11 of the Act as well as not treating the assessee state body under artic

The order continues below.

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