MANGALAYATAN UNIVERSITY,JABALPUR, MADHYA PRADESH vs. LD. CIT (EXEMPTION), BHOPAL, BHOPAL, MADHYA PRADESH

ITA 96/JAB/2024Status: DisposedITAT Jabalpur22 July 2025AY 2022-23Bench: the date of hearing of the appeal." The facts of the case are, that the assessee applied in Form No.10AB for registration under section 12AB of the Income Tax Act. While examining this application, the ld. CIT (Exemption) observed that the assessee had entered into an agreement on 16.03.2022 with Helpage Finlease Limited for a loan of Rs.42,00,000/- @ 7.5% per annum w.e.f. 1.04.2022. However, in the ledger account submitted by the assessee, no interest was found to be paid and interest of o1 pages

AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(Exemption)'s conclusion regarding incorrect interest payable was premature as all facts were not on record. Regarding CSR violation, the Tribunal noted that the assessee received funds, applied for registration promptly, and eventually obtained it. The Tribunal questioned whether belated compliance amounted to a violation of law or mere irregularity, suggesting that such determination should be made by authorities implementing the Companies Act.

What were the facts?

The assessee, Mangalayatan University, applied for registration under Section 12AB of the Income Tax Act. The CIT(Exemption) rejected the application based on the grounds that the assessee did not maintain proper books of accounts and had violated CSR Rules by receiving CSR funds before obtaining registration. The assessee argued that the loan interest was confirmed and the CSR compliance was belated but not a violation.

What were the issues?

Whether the rejection of the registration application under Section 12AB was justified based on alleged improper maintenance of accounts and violation of CSR rules.

Which sections of the Income-tax Act were involved?

12AB(1)(ac)(iii), 12AB(1)(b)(i)(B), 12AB(4)(f)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JABALPUR BENCH, JABALPUR

Hearing: 20.05.2025Pronounced: 22.07.2025

PER NIKHIL CHOUDHARY, A.M.

This is an appeal filed by the assessee against the order of the learned CIT (Exemption), Bhopal against the rejection of the application filed by the assessee under section 12AB(1)(ac)(iii) of the Income Tax Act. The grounds of appeal are under:- “1. The learned Commissioner of Income Tax (Exemption) Bhopal, has erred in rejecting the application under section 12AB(1)(ac)(iii) of the Act filed by the Appellant Trust (M/s Mangalayatan University) on the ground that proper books of accounts have not been maintained the Appellant Trust. Based on the facts and circumstances of the case, the action of Ld. CIT(Exemption) of rejecting the application filed u/s 12AB(1)(ac)(iii) of t

The order continues below.

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