Ahmedabad Rana Caste Association v. CIT

82 ITR 704Supreme Court of India1971#2276 most cited

What is Ahmedabad Rana Caste Association v. CIT authority for?

An intention to benefit a section of the public, as distinguished from a special individual, is sufficient for a trust to be considered for charitable registration and exemptions. This applies even if the beneficiaries belong to a specific caste, community, or professional group, allowing the trust to qualify as serving a general public utility under Section 2(15).

51

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

Ahmedabad Rana Caste Association v CIT · 82 ITR 704 · Section 12A · Section 12AB · Section 80G · Section 2(15) · Section 13(1)(b) · general public utility · benefit a section of the public · trust for specific caste · charitable registration · tax exemption

Issues it is cited on

Judgments citing Ahmedabad Rana Caste Association v. CIT

MADHAV UNIVERSITY,PINDWARA, SIROHI vs. CIT(EXEMPTION), JAIPUR

In the result, both the appeals filed by the assessee bearing ITA No

ITA 789/JODH/2024[2024-25]Status: DisposedITAT Jodhpur22 Aug 2025AY 2024-25

Bench: Dr. Mitha Lal Meena, Hon'Ble & Shri Anikesh Banerjee, Hon'Bleι.Τ.Α No.789 &790/Jodh/2024 (Assessment Year:2024-25) Madhav University Vs Commissioner Of Income-Tax, Exemption, Jaipur Pindwara, Madhav Hills, Nh 27, Vpo Bharja, Pindwara, Sirohi Rajasthan-307023 Pan: Aasam7855L Shri Amit Kothari Shri M.K. Jain, Cit(Dr.) Present For Assessee Present For Revenue Date Of Hearing 20/08/2025 Date Of Pronouncement 22/08/2025 Order Per Bench: The Instant Appeals Of The Assessee Filed Against The Order Of The Learned Commissioner Of Income-Tax (Exemption), Jaipur (For Brevity, 'Ld.Cit(E)'] Order Passed Under Section 12Ab Of The Income-Tax Act, 1961 (In Short, 'The Act') & Order Passed Under Section 80G(5) Of The Act, Date Of Orders 30/09/2024. 2. Act Both The Appeals Related To Registration Under Section 12Ab& 80G Of The

Section 11Section 12ASection 3(2)Section 80Section 80G(5)

…education as a public good. The appellant. therefore, fully comply with the principles laid down in the New Noble Education Society case. 2.13. Your kind attention is also invited towards the following decisions: Ahmedabad Rana Caste Association v. CIT (1971) 82 ITR 704 (SC) emphasized that tax exemption is based on charitable activities, not the legal structure of the entity. CIT v. Dawoodi Bohra Jamat (2014) 364 ITR 31 (SC) reiterated that the focus for 12AA registration is on the genuineness of the charitable activities. 3. Separation from Past Claims of Sponsoring Body 3.1. Any past claims under Sec. 11/12 we…

ICLEI SOUTH ASIA GROUP GRATUITY TRUST,NEW DELHI vs. CIT(E), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 762/DEL/2021[2020-21]Status: DisposedITAT Delhi01 Jun 2023AY 2020-21

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2018-19 Assessment Year 2021-22 Icrw Group Gratuity Trust, Vs Cit (Exemptions), C-59, Ground Floor, Delhi. South Extension Part Ii, New Delhi 110 049 Pan: Aabti3510L Assessment Year: 2020-21 Iclei South Asia Group Gratuity Trust, Vs Cit (Exemptions), C-3, Lower Ground Floor, Delhi Green Park Extension, New Delhi – 110 016. Pan: Aabti7567H (Appellant) (Respondent) Assessee By : Shri Anand Chaudhuri, Advocate Revenue By : Sh. Mohd. Gayasuddin Ansari,Cit,Dr Date Of Hearing : 17.05.2023 Date Of Pronouncement : 01.06.2023

For Appellant: Shri Anand Chaudhuri, AdvocateFor Respondent: Sh. Mohd. Gayasuddin Ansari,CIT,DR
Section 12ASection 25

…6. The present proceedings before us are against the giving effect order passed by the ld.CIT(E) on 31.03.2022. We find that the ld.CIT(E) had stated that the judgement of the Hon’ble Supreme Court in the case of Ahmedabad Rana Caste Association, reported in 82 ITR 704 (relied upon by the assessee) would not be applicable in the present case as Ahmedabad Rana Caste Association was incorporated for the purpose of management of movable and immovable properties of Rana community of the city of Ahmedabad, doing acts to improve education in the community and to give medical help to the community, etc. However, in the…

ICRW GROUP GRATUITY TRUST,NEW DELHI vs. CIT(E), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 761/DEL/2021[2021-22]Status: DisposedITAT Delhi01 Jun 2023AY 2021-22

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2018-19 Assessment Year 2021-22 Icrw Group Gratuity Trust, Vs Cit (Exemptions), C-59, Ground Floor, Delhi. South Extension Part Ii, New Delhi 110 049 Pan: Aabti3510L Assessment Year: 2020-21 Iclei South Asia Group Gratuity Trust, Vs Cit (Exemptions), C-3, Lower Ground Floor, Delhi Green Park Extension, New Delhi – 110 016. Pan: Aabti7567H (Appellant) (Respondent) Assessee By : Shri Anand Chaudhuri, Advocate Revenue By : Sh. Mohd. Gayasuddin Ansari,Cit,Dr Date Of Hearing : 17.05.2023 Date Of Pronouncement : 01.06.2023

For Appellant: Shri Anand Chaudhuri, AdvocateFor Respondent: Sh. Mohd. Gayasuddin Ansari,CIT,DR
Section 12ASection 25

…6. The present proceedings before us are against the giving effect order passed by the ld.CIT(E) on 31.03.2022. We find that the ld.CIT(E) had stated that the judgement of the Hon’ble Supreme Court in the case of Ahmedabad Rana Caste Association, reported in 82 ITR 704 (relied upon by the assessee) would not be applicable in the present case as Ahmedabad Rana Caste Association was incorporated for the purpose of management of movable and immovable properties of Rana community of the city of Ahmedabad, doing acts to improve education in the community and to give medical help to the community, etc. However, in the…

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