CIT v. Dawoodi Bohra Jamat

364 ITR 31Supreme Court of India2014#1387 most cited

What is CIT v. Dawoodi Bohra Jamat authority for?

A trust's objects, even if based on religious tenets, can qualify as charitable for tax exemptions if its benefits are not exclusively restricted to a particular religious community or caste.

83

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Dawoodi Bohra Jamat · Section 13(1)(b) · Section 11 · Section 12A · Section 2(15) · charitable trust · religious trust · general public utility · benefit not restricted to particular community · trust registration · income tax exemption · objects of trust

Also reported as

222 Taxmann 228

Sections most often in play

Section 12ASection 12ABSection 11Section 13(1)(b)Section 80GSection 2(15)Section 80G(5)Section 12A(1)(ac)(iii)

Issues it is cited on

section 13(1)(b)section 80g(5b)section 13(1)section 115bbccorpus fundsection 80g(2)anonymous donationsection 11(1)(d)section 12ab(4)section 12ab(1)(b)(ii)section 11(5)section 11(1)(a)

Judgments citing CIT v. Dawoodi Bohra Jamat

KHAJA EDUCATION SOCIETY ,KALABURGI vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), BANGALORE

In the result the appeals are allowed for statistical purposes

ITA 1608/BANG/2025[NA ]Status: DisposedITAT Bangalore24 Feb 2026

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Smt. N. Hemalatha, CIT(DR)(ITAT), Bengaluru
Section 12Section 80

…of the Act to the assessee as a religious trust and consequently denied the recognition under section 80 G of the Act. He submits that the issue is squarely covered by the decision of the Honourable Supreme Court in case of CIT v. Dawoodi Bohara Jamat (2014) 364 ITR 31 (SC) wherein it is required to be established whether the entity is a religious trust or a charitable trust with the purpose behind the establishment of the society, objects of the trust and the beneficiaries. He submitted that the objects of the assessee society are providing secular education particularly for Muslim students and not confined to…

KHAJA EDUCATION SOCIETY ,KALABURGI vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), BANGALORE

In the result the appeals are allowed for statistical purposes

ITA 1607/BANG/2025[NA]Status: DisposedITAT Bangalore24 Feb 2026

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Smt. N. Hemalatha, CIT(DR)(ITAT), Bengaluru
Section 12Section 80

…of the Act to the assessee as a religious trust and consequently denied the recognition under section 80 G of the Act. He submits that the issue is squarely covered by the decision of the Honourable Supreme Court in case of CIT v. Dawoodi Bohara Jamat (2014) 364 ITR 31 (SC) wherein it is required to be established whether the entity is a religious trust or a charitable trust with the purpose behind the establishment of the society, objects of the trust and the beneficiaries. He submitted that the objects of the assessee society are providing secular education particularly for Muslim students and not confined to…

GLOBAL COUNCIL OF ZOROASTRIANS TRUST,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI

ITA 4930/MUM/2025[N.A.]Status: DisposedITAT Mumbai06 Feb 2026

Bench: Shri Saktijit Dey & Shri Jagadish

Section 11Section 12ASection 12A(1)(ac)Section 13(1)(b)Section 80GSection 80G(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI JAGADISH, ACCOUNTANT MEMBER I.T.A. No. 4928/Mum/2025 & I.T.A. No. 4930/Mum/2025 Global Council of Zoroastrians Vs. CIT (Exemptions) Trust Room No.601, 6th Floor, E-604,Remi Bizcourt, Off Veera Desai Road, Andheri West, Cumballa Hill MTNL TE Mumbai-400053 Building, Peddar Road, Cumballa Hill, Mumbai-400026 PAN: [AAETG3442J] (Appellant) (Respondent) Appellant by Shri Dharan Gandhi & Vinita Nara Respondent by Shri Arun Kanti Datta - CIT DR Date of Hearing 14.01.2026 Date of Pronouncement 06.02.2026 ORDER P…

GLOBAL COUNCIL OF ZOROASTRIANS TRUST,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI

ITA 4928/MUM/2025[N.A.]Status: DisposedITAT Mumbai06 Feb 2026

Bench: Shri Saktijit Dey & Shri Jagadish

Section 11Section 12ASection 12A(1)(ac)Section 13(1)(b)Section 80GSection 80G(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI JAGADISH, ACCOUNTANT MEMBER I.T.A. No. 4928/Mum/2025 & I.T.A. No. 4930/Mum/2025 Global Council of Zoroastrians Vs. CIT (Exemptions) Trust Room No.601, 6th Floor, E-604,Remi Bizcourt, Off Veera Desai Road, Andheri West, Cumballa Hill MTNL TE Mumbai-400053 Building, Peddar Road, Cumballa Hill, Mumbai-400026 PAN: [AAETG3442J] (Appellant) (Respondent) Appellant by Shri Dharan Gandhi & Vinita Nara Respondent by Shri Arun Kanti Datta - CIT DR Date of Hearing 14.01.2026 Date of Pronouncement 06.02.2026 ORDER P…

SHREE DIGMBER JAIN TRUST WAGHOLI,PUNE vs. CIT(EXEMPTION), PUNE, PUNE

In the result, both the appeals in ITA Nos

ITA 2511/PUN/2025[-]Status: DisposedITAT Pune17 Dec 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Premal GandhiFor Respondent: Smt. Indira R. Adakil
Section 12ASection 12A(1)(ac)Section 80G

…) and hence not eligible for registration, overlooking that the reference to 'Jain' in the trust name or philosophy does not restrict benefits to members of a particular caste or religion, and judicial precedents support this view (CIT v. Dawoodi Bohra Jamat, 364 ITR 31 (SC)). 5. That the learned CIT (Exemption) erred in rejecting the application solely based on minor procedural non-compliance, despite the appellant having made substantial and bona fide compliance, thereby violating the principles of natural justice. 6. That the learned CIT (Exemption) failed to provide adequate opportunity of being heard and pas…

SHREE DIGMBER JAIN TRUST WAGHOLI,PUNE vs. CIT(EXEMPTION), PUNE, PUNE

In the result, both the appeals in ITA Nos

ITA 2510/PUN/2025[-]Status: DisposedITAT Pune17 Dec 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Premal GandhiFor Respondent: Smt. Indira R. Adakil
Section 12ASection 12A(1)(ac)Section 80G

…) and hence not eligible for registration, overlooking that the reference to 'Jain' in the trust name or philosophy does not restrict benefits to members of a particular caste or religion, and judicial precedents support this view (CIT v. Dawoodi Bohra Jamat, 364 ITR 31 (SC)). 5. That the learned CIT (Exemption) erred in rejecting the application solely based on minor procedural non-compliance, despite the appellant having made substantial and bona fide compliance, thereby violating the principles of natural justice. 6. That the learned CIT (Exemption) failed to provide adequate opportunity of being heard and pas…

ANANDABAVA SEVA SANSTHA GAUSHALA TRUST JAMNAGAR,JAMNAGAR vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 31/RJT/2025[2024-25]Status: DisposedITAT Rajkot21 Oct 2025AY 2024-25

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 31/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2024-25) (Hybrid Hearing) Anandbava Seva Sanstha Gaushala Trust, The Pr. Commissioner Of Income Vs. Gopal Bhuvan No, Anandbava Chakalo, Tax (E), Jamnagar 361001 Ahmedabad 380015 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaata2817K (Appellant) (Respondent) Appellant By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 22/07/2025 Date Of Pronouncement : 21/10/2025

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. Sr. (DR)
Section 2(15)Section 80(5)Section 80GSection 80G(5)Section 80G(5)(iii)

…ded to the visitors. Therefore, if the same is excluded from the pooja expenses then the expenditure of pooja expenses is less than 5% of the total receipts. i. The Hon'ble Supreme Court in CIT v. Dawoodi Bohra Jamat, [2014] 43 taxmann.com 243/222 Taxman 228/364 ITR 31 (SC) had observed that the objects of trust as declared in the Trust Deed would govern its right of exemption under sections 11 and 12 of the Act. The Hon'ble Supreme Court also recognized the creation or establishment of trust for either religious or charitable or both religious charitable purposes. By looking at the objects of the trust, it had…

ADITYA BIRLA EDUCATION TRUST,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4474/MUM/2025[NA]Status: DisposedITAT Mumbai19 Sept 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Saurabh Soparkar (virtually appear), Shri Yogesh Thar, ShriFor Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Section 11Section 12ASection 12A(1)(ac)Section 13(1)(b)

…f general public utility.” ii. The above decision of the Hon’ble Gujarat High Court was affirmed by the Hon’ble Supreme Court in CIT v. Ahmedabad Rana Caste Association [1983] 140 ITR 1 19 Aditya Birla Education Trust iii. CIT v. Dawoodi Bohara Jamat [2014] 364 ITR 31 (SC). The relevant extract of the decision is reproduced as under: - “49. In the present case, the objects of the respondent- trust are based on religious tenets under Quran according to religious faith of Islam. We have already noticed that the perusal of the objects and purposes of the respondent-trust would clearly demonstrate that the activiti…

SHREEJI JANSEVA KHANDI GRAMODHYOG SANGH,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 92/AHD/2025[NA]Status: HeardITAT Ahmedabad26 Aug 2025

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Alpesh Shah, C.AFor Respondent: Shri R P Rastogi, CIT DR
Section 12A

…t, (ii) whether the activities are in consonance with the objects of the trust and (iii) whether other laws material for achieving the objects were complied with. 4. Placing reliance on the judgments of the Hon’ble Supreme Court in CIT v. Dawoodi Bohra Jamat (364 ITR 31) and New Noble Educational Society v. CIT (448 ITR 594), the CIT(E) rejected the Shreeji Janseva Khandi Gramodyog Sangh vs. CIT(E) Asst.Year –N.A. - 3– application in Form 10AB and also cancelled the provisional registration. 5. Aggrieved by the order of CIT(E), the assessee is in appeal before us raising following grounds of appeal: 1. The lear…

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)

…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 were by Manav Bharti Foundation, which is a distinct legal entity and is only the sponsoring body. 3.2. Madhav University commenced operations independently…

SHREE AATH PARAGANA GURJAR PRAJAPATI SAMAJ TRUST,AHMEDABAD vs. CIT(EXEMPTION), AHMEDABAD, VEJALPUR, AHMEDABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2025/AHD/2024[N.A.]Status: DisposedITAT Ahmedabad12 Aug 2025

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : - Shree Aath Paragana Gurjar Prajapati The Cit(Exemption) Samaj Trust Vs. Vejalpur Prajapati Bhavan Chatrala Ahmedabad. Sola Railway Over Bridge Naittar Chede, Sola Ghatlodia. Pan : Abfts 9086 E (Applicant) (Responent) : Assessee By Shri Prakash D. Shah & Shri Saiyam Shah, Ar : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025

Section 12ASection 12A(1)(ac)

…the stage of assessment and not at the time of grant of registration under section 12AB. 3.4 The CIT(Exemption), however, did not accept the assessee’s submissions. Referring to the decision of the Hon’ble Supreme Court in CIT v. Dawoodi Bohra Jamat [(2014) 364 ITR 31 (SC) / 43 taxmann.com 243], the CIT(Exemption) held that the bar under section 13(1)(b) is applicable even at the stage of registration, since the provision relates to the eligibility of the trust to claim exemption under section 11, and such eligibility is a relevant criterion to be examined at the time of registration under section 12A/12AB. It…

INFANT JESUS CHURCH,KOCHI vs. CIT(EXEMPTION), ERNAKULAM

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 898/COCH/2024[2023-24]Status: DisposedITAT Cochin09 Jun 2025AY 2023-24

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : Na

For Respondent: Shri Anil Kumar P J
Section 11Section 12ASection 12A(1)Section 13(1)(a)

…n of the honorable Gujarath High Court in The Commissioner of Income Tax Exemption Ahmedabad Vs Jamiatul Banaat Tankaria where the Court relied on the decision of the Honorable Apex Court in Commissioner of Income Tax Vs Dawoodi Bohara Jamat reported as (2014)364 ITR 31 (SC). 5. Such other grounds as may be raised at the time of hearing the appeal.” 2. The assessee filed this appeal with a delay of 31 days and also filed an application to condone the said delay. The assessee submitted that they had not received the real time alert in their mobile and the appellant being a church they are also busy in organising…

CHRIST THE KING CHURCH,KOCHI vs. CIT(EXEMPTION), KOCHI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 897/COCH/2024[2023-24]Status: DisposedITAT Cochin28 May 2025AY 2023-24

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : Na

For Respondent: Shri Anil Kumar P J
Section 12ASection 13(1)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH : COCHIN BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment Year : NA Christ the King Church, The Commissioner of 14/706, Varapuzha, Income Tax (Exemption), Kochi. Kochi. PAN: AACTC7709E Vs. APPELLANT RESPONDENT : Shri Anil Kumar P J, Assessee by Advocate : Shri Suresh Sivanandan Revenue by IRS, CIT-DR : 12-03-2025 Date of Hearing : 28-05-2025 Date of Pronouncement ORDER PER SOUNDARARAJAN K., JUDICIAL MEMBER This is an appeal filed by the assessee challenging the order of the Ld.CIT(E)-Kochi dated 31/07/2024…

SHRI SHESHAVTAR 1008 SHRI KALLAJI VEDPITH EVAM SHODH SANSTHAN,NIMBAHERA, CHITTORGARH vs. ITO EXEMPTION WARD, UDAIPUR, AAYKAR BHAWAN, UDAIPUR

In the result, appeal of the assessee is partly allowed

ITA 268/JODH/2024[2017-18]Status: DisposedITAT Jodhpur01 Apr 2025AY 2017-18

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Sunil Surana, CA &For Respondent: Shri Karni Dan, Addl. CIT, Sr.DR
Section 115BSection 12ASection 142Section 143(1)Section 143(2)Section 234BSection 234DSection 250

…om anonymous donation. The assesseesansthanis religious cum charitable trust, the term religious and charitable is defined by honourable Apex Court in the case of Commissioner of Income tax, Ujjain v. Dawoodi Bohara Jamat (SC) (SC)[2014] 222 Taxman 228 [2014] 364 ITR 31 [2014] 268 CTR 1: (2014) 102 DTR 361:- “Para 35. Unlike the phrase "charitable purpose", "religious purpose" is not defined under the Act. According to lexicographers, the term religious would mean "of or relating to religion." (Merriam Webster Dictionary, Macmillan English Dictionary). The Shorter Oxford English Dictionary defines the term as fol…

TREHAN SEVA BHARTI CHARITABLE TRUST,ALWAR vs. CIT(E), JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed

ITA 1027/JPR/2024[NA]Status: DisposedITAT Jaipur15 Jan 2025
Section 12(1)Section 12ASection 80G

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nJAIPUR BENCH “B”, JAIPUR\nBEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND\nSHRI GAGAN GOYAL, ACCOUNTANT MEMBER\nITA Nos.1027 & 1028/JPR/2024\n\nTrehan Seva Bharti Charitable Trust,\nKalani & Co., 5th Floor, Milestone Building\nGandhi Nagar Turn, Tonk Road,\nJaipur - 302 015.\nPAN No.:AADTT8776F\nAppellant\n\nVs.\n\nCIT Exemption,\nJaipur - 302 015.\nRespondent\n\nAppellant by\n: Mr. P. C. Parwal, CA, Ld. AR\nRespondent by\n: Ms. Alka Gautam, CIT, Ld. DR\nDate of hearing\n: 08/01/2025\nDate of pronouncement : 15/01/2025\n\nORDER\nPER GAGAN GOYAL, A.M:\n\nTh…

PORWAL YUVAK SANGH KOTA,KOTA vs. CIT EXEMPTION, JAIPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 708/JPR/2024[2023-24 ]Status: DisposedITAT Jaipur20 Dec 2024

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

Section 12ASection 13

…IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “B”, JAIPUR BEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ITA No. 708/JPR/2024 (A.Y.2023-24) Porwal Yuvak Sangh Kota, 77-78 Porwal Bhawan, Vallabh Bari, Kota- 324006. PAN No.:AAAAP7068G Appellant Vs. Appellant CIT Exemption, Jaipur - 302 001. Respondent Appellant by Respondent by Date of hearing Date of pronouncement : Mr. Sarwan Kumar Gupta, Adv., Ld. AR : MS. Alka Gautam, CIT Ld. DR. (V.H) : 12/12/2024 : 20/12/2024 PER GAGAN GOYAL, A.M: ORDER This appeal by assessee is directed against the order of CIT (Exemption), Jaipurda…

SILA FOR CHANGE FOUNDATION ,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

In the result appeals filed by the assessee stand dismissed

ITA 4275/MUM/2024[--]Status: DisposedITAT Mumbai20 Dec 2024

Bench: Smt Beena Pillai & Shri Prabhash Shankar & Sila For Change Foundation Commissioner Of Income-Tax A-301, 3Rd Floor, (Exemption) Neelam Centre, 601, 6Th Floor, Plot 249A, Worli, Cumballa Hill, Mumbai- 400030. Mtnl Building, Pan: Abgcs5333L Vs. Peddar Road, Dr. Gopalrao Deshmukh Marg, Cumballa Hill, Maharashtra- 400026. (Appellant) (Respondent)

For Appellant: Shri Mandar Vaidya- AdvocateFor Respondent: Dr. Kishore Dhule- CIT D.R
Section 12A(1)(ac)

…ies outside India and money is spent outside India but nevertheless the ‘charitable purpose’ is served in India . He also placed reliance on the following decision in support of his arguments:- “1. CIT V/s. Dawoodi Bohara Jamat [2014] 43 Taxmann.com 243 (SC): 364 ITR 31 (SC) 2. Shri Sachay Mataji Mandir Vikas Trust v/s. CIT(E) [2024] 165 Taxmann.com 306 (Rajkot-Trib.) ITA No.4274 & 4275/MUM/2024 Sila for Change Foundation; 3. National Real Estate Development Council V/s. CIT (E) ITA/487/Ahd./2024” 3.3. On the contrary the Ld.DR submitted that the objectin clause 12 clearly states that, it would provide support an…

SILA FOR CHANGE FOUNDATION ,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

In the result appeals filed by the assessee stand dismissed

ITA 4274/MUM/2024[--]Status: DisposedITAT Mumbai20 Dec 2024

Bench: Smt Beena Pillai & Shri Prabhash Shankar & Sila For Change Foundation Commissioner Of Income-Tax A-301, 3Rd Floor, (Exemption) Neelam Centre, 601, 6Th Floor, Plot 249A, Worli, Cumballa Hill, Mumbai- 400030. Mtnl Building, Pan: Abgcs5333L Vs. Peddar Road, Dr. Gopalrao Deshmukh Marg, Cumballa Hill, Maharashtra- 400026. (Appellant) (Respondent)

For Appellant: Shri Mandar Vaidya- AdvocateFor Respondent: Dr. Kishore Dhule- CIT D.R
Section 12A(1)(ac)

…ies outside India and money is spent outside India but nevertheless the ‘charitable purpose’ is served in India . He also placed reliance on the following decision in support of his arguments:- “1. CIT V/s. Dawoodi Bohara Jamat [2014] 43 Taxmann.com 243 (SC): 364 ITR 31 (SC) 2. Shri Sachay Mataji Mandir Vikas Trust v/s. CIT(E) [2024] 165 Taxmann.com 306 (Rajkot-Trib.) ITA No.4274 & 4275/MUM/2024 Sila for Change Foundation; 3. National Real Estate Development Council V/s. CIT (E) ITA/487/Ahd./2024” 3.3. On the contrary the Ld.DR submitted that the objectin clause 12 clearly states that, it would provide support an…

SREE DHARMA SASTHA HARIHARA SEVA CHARITABLE TEMPLE TRUST,ERUMELY vs. CIT (EXEMPTION), KOCHI

In the result, the appeal of the assessee is allowed

ITA 62/COCH/2024[Not Applicable]Status: DisposedITAT Cochin09 Dec 2024

Bench: Shri Inturi Rama Rao, Am & Shri Soundrarajan K., Jm

For Appellant: ------- None -------For Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 11Section 12ASection 12A(1)(ac)Section 13Section 13(1)(b)

…nnot be granted registration u/s. 12A of the Act as held by the ITAT, Pune Bench in the case of Diocese of Pune (CNI) vs. CIT, ITA No. 1352/Pune/2014 dated 31.03.2015 wherein it was held as under: “11. The Hon'ble Supreme Court in Dawoodi Bohra Jamat, (2014) 364 ITR 31 (SC) had observed that the objects of trust as declared in the Trust Deed would govern its right of exemption under sections 11 and 12 of the Act. The Hon'ble Supreme Court also recognized the creation or establishment of trust for either religious or charitable or both religious and charitable purposes. By looking at the objects of the trust, it…

SREE DHARMA SASTHA HARIHARA SEVA CHARITABLE TEMPLE TRUST,ERUMELY vs. CIT (EXEMPTION), KOCHI

In the result, the appeal of the assessee is allowed

ITA 61/COCH/2024[2023-24 to 2027-28]Status: DisposedITAT Cochin09 Dec 2024

Bench: Shri Inturi Rama Rao, Am & Shri Soundrarajan K., Jm

For Appellant: ------- None -------For Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 11Section 12ASection 12A(1)(ac)Section 13Section 13(1)(b)

…nnot be granted registration u/s. 12A of the Act as held by the ITAT, Pune Bench in the case of Diocese of Pune (CNI) vs. CIT, ITA No. 1352/Pune/2014 dated 31.03.2015 wherein it was held as under: “11. The Hon'ble Supreme Court in Dawoodi Bohra Jamat, (2014) 364 ITR 31 (SC) had observed that the objects of trust as declared in the Trust Deed would govern its right of exemption under sections 11 and 12 of the Act. The Hon'ble Supreme Court also recognized the creation or establishment of trust for either religious or charitable or both religious and charitable purposes. By looking at the objects of the trust, it…

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