THE JEWELLERS AND DIAMOND TRADERS ASSOCIATION,MADRAS vs. CIT, EXEMPTIONS,, CHENNAI

ITA 1093/CHNY/2025Status: DisposedITAT Chennai22 September 2025Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)1 pages
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What did the Tribunal hold?

The ITAT held that the CIT(Exemptions) erred in rejecting the registration application by delving into issues of taxability, which is beyond his scope at the registration stage. The Tribunal found that the assessee's activities fall within the ambit of 'advancement of any other object of general public utility'.

What were the facts?

The assessee, The Jewellers and Diamond Traders Association, applied for registration under Section 12AB of the Income Tax Act. The CIT(Exemptions) rejected the application, opining that the assessee's objects were for the benefit of its members and not the general public, thus not qualifying as a charitable purpose.

What were the issues?

Whether the CIT(Exemptions) has the power to examine taxability of income at the stage of granting registration under Section 12AB, and if the assessee's objects qualify as 'general public utility'.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 2(15),Section 11,Section 12,Section 13

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Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRI S.R. RAGHUNATHA

For Respondent: Mr. Bipin C.N., CIT
Hearing: 24.07.2025Pronounced: 22.09.2025

PER S. R. RAGHUNATHA, ACCOUNTANT MEMBER:

This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Exemption), Chennai 21.03.2025 rejecting application for registration of the Trust u/s.12AB of the Income Tax Act, 1961 (“the Act” for short).

2.

The grounds raised by the assessee are as follows:

:-2-: ITA. No:1093 /Chny/2025

01.

The Appellant falls under a “Class of Public” as per the Gujarat High Cour

The order continues below.

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