DODDABALLAPUR PLANNING AUTHORITY,BANGALORE vs. ITO, EXEMPTION, WARD-3, BANGALORE

ITA 2115/BANG/2024Status: DisposedITAT Bangalore25 June 2025AY 2019-20Bench: SHRI LAXMI PRASAD SAHU (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)23 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that valid registration under Section 12AA/12AB of the Act is a mandatory precondition for claiming exemption under Section 11. Therefore, the assessee's claim for exemption on betterment and rejuvenation fees was not admissible.

What were the facts?

The assessee, Doddaballapur Planning Authority, claimed exemption under Section 11 of the Income Tax Act for betterment and rejuvenation fees. The Income Tax CPC denied this claim for AY 2019-20 and 2021-22 due to failure to file Form 9A and lack of valid registration under Section 12A/12AB.

What were the issues?

Whether the assessee is eligible for exemption under Section 11 of the Income Tax Act without valid registration under Section 12A/12AB, and whether betterment and rejuvenation fees constitute capital receipts eligible for such exemption.

Which sections of the Income-tax Act were involved?

Section 11,Section 12,Section 12A,Section 12AA,Section 12AB,Section 2(15)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(3)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, “C’’BENCH: BANGALORE

Before: SHRI LAXMI PRASAD SAHU & SHRI KESHAV DUBEY

For Respondent: Ms. Neha Sahay, D.R
Hearing: 07.04.2025Pronounced: 25.06.2025

PER KESHAV DUBEY, JUDICIAL MEMBER:

These appeals at the instance of assessee are directed against the orders of ld. Addl/JCIT(A), Panchkula both dated 25.10.2024 vide DIN & Order No. ITBA/APL/S/250/2024-25/1069938421(1) for the assessment year 2019-20 & vide DIN & Order No. ITBA/APL/S/250/2024-25/1069936312(1) for the assessment year 2021-22 passed u/s 250 of the Income Tax Act, 1961 (in short “The Act”). Since the issue in both these appeals is common, these are clubbed together, heard together and disposed

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 11

All 7,190 judgments and leading authorities on Section 11 →

Recent GST High Court judgments

Search GST case law →