DOLPHIN CLUB,CHENNAI vs. CIT EXEMPTIONS, CHENNAI

ITA 3107/CHNY/2024Status: DisposedITAT Chennai23 February 2026Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R.RAGHUNATHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the CIT(Exemptions) exceeded their jurisdiction by conducting a detailed examination of receipts and expenditure patterns at the registration stage. The Tribunal found that the assessee's activities constituted systematic training in sports, falling under 'education' as per Section 2(15), and the genuineness of activities was evidenced by records.

What were the facts?

The assessee, Dolphin Club, applied for registration under Section 12AB of the Income Tax Act, 1961, by filing Form 10AB. The CIT(Exemptions) rejected the application, citing that the activities were not solely for educational purposes and were conducted on commercial lines.

What were the issues?

Whether the CIT(Exemptions) erred in rejecting the registration application by delving into aspects beyond the scope of examining the objects and genuineness of activities, and whether the assessee's activities qualify as 'education' under Section 2(15).

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

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

Pronounced: 23.02.2026

PER MANU KUMAR GIRI, Judicial Member:

This captioned Appeal filed by the Assessee is directed against the order of the Ld. Commissioner of Income Tax (Exemption), Chennai, [CIT(E)] dated 30.10.2024. 2. Assessee has raised the following grounds of appeal:

1.

The order of the CIT(Exemptions) dated 30.10.2024 vide DIN & Order No. ITBA/EXM/F/EXM45/2024- 25/1070052820(1) for the above mentioned Assessment Year is contrary to law, fact and in circumstances of the case

The order continues below.

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