DIT (Exemptions) v. Mool Chand Khairati Ram Trust

339 ITR 622High Court2011#3803 most cited

What is DIT (Exemptions) v. Mool Chand Khairati Ram Trust authority for?

The order of the Commissioner of Income Tax (CIT) passed under Section 12A of the Income Tax Act is quasi-judicial in nature. Prior to October 1, 2004, there was no express provision in the Act granting the CIT the power to cancel registration.

31

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

DIT v. Mool Chand Khairati Ram Trust · Section 12A · cancellation of registration · quasi-judicial order · power of cancellation

Also reported as

11 Taxmann.com 42199 Taxmann 1

Issues it is cited on

section 12aa(3)section 256(2)section 12a(a)cancellation of registrationsection 35(1)(ii)section 256section 10(1)section 12ab(4)section 12a(1)(ac)(i)section 35(1)scheme of arrangementsection 21

Judgments citing DIT (Exemptions) v. Mool Chand Khairati Ram Trust

Agra Obstetrical and Gynaecological Society, Agra vs. PCIT, Central, Pune

ITA 549/PUN/2023[2022-23]Status: DisposedITAT Pune26 Mar 2025AY 2022-23

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.518/Pun/2023 1. Poona Obstetrics & Gynaecological Society, 302/303, Dr. Neety Mandke Ima House, Tilak Road, Shukrawar Peth, Pune 411 002, Maharashtra Pan : Aaatp1435C Vs. Pr.Cit (Central), Pune Appellant Respondent आयकर अपील सं. / Ita No.522/Pun/2023 2. The Mumbai Obstetrics & Gynaecological Society, C-114, Ist Floor, D-Wing Entrance, Trade World, Kamala City, Senapati Bapat Marg, Low Parel (W), Mumbai-400 013 Maharashtra Pan : Aaatt4562C Vs. Pr.Cit (Central), Pune Appellant Respondent आयकर अपील सं. / Ita No.549/Pun/2023 3. Agra Obstetrical & Gynaecological Society, 84, M.G. Road, Agra 282 010, Uttar Pradesh Pan : Aabta6327K Vs. Pr.Cit (Central), Pune Appellant Respondent आयकर अपील सं. / Ita No.417/Pun/2023 4. Aids Society Of India, Ground Floor, Maharukh Mandsion, Alibhai Premji Marg, Grant Road (E), Mumbai 400 007 Maharashtra Pan : Aabta4129R Vs. Principal Commissioner Of Income-Tax (Central), Pune Appellant Respondent 2

Section 12A

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Тахman 1/339 ITR 622, Uttaranchal High Court in the case of Welhom Boys' School Society v. CBDT [2006] 285 ITR 74//2007) 158 Тахтап 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [20091.315 ITR 382 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section 2…

Aids Society of India, Mumbai vs. The Principal Commissioner of Income Tax (Central), Pune

ITA 417/PUN/2023[-]Status: DisposedITAT Pune26 Mar 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.518/Pun/2023 1. Poona Obstetrics & Gynaecological Society, 302/303, Dr. Neety Mandke Ima House, Tilak Road, Shukrawar Peth, Pune 411 002, Maharashtra Pan : Aaatp1435C Vs. Pr.Cit (Central), Pune Appellant Respondent आयकर अपील सं. / Ita No.522/Pun/2023 2. The Mumbai Obstetrics & Gynaecological Society, C-114, Ist Floor, D-Wing Entrance, Trade World, Kamala City, Senapati Bapat Marg, Low Parel (W), Mumbai-400 013 Maharashtra Pan : Aaatt4562C Vs. Pr.Cit (Central), Pune Appellant Respondent आयकर अपील सं. / Ita No.549/Pun/2023 3. Agra Obstetrical & Gynaecological Society, 84, M.G. Road, Agra 282 010, Uttar Pradesh Pan : Aabta6327K Vs. Pr.Cit (Central), Pune Appellant Respondent आयकर अपील सं. / Ita No.417/Pun/2023 4. Aids Society Of India, Ground Floor, Maharukh Mandsion, Alibhai Premji Marg, Grant Road (E), Mumbai 400 007 Maharashtra Pan : Aabta4129R Vs. Principal Commissioner Of Income-Tax (Central), Pune Appellant Respondent 2

For Respondent: Shri Ajay Kumar Keshari
Section 12A

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Тахman 1/339 ITR 622, Uttaranchal High Court in the case of Welhom Boys' School Society v. CBDT [2006] 285 ITR 74//2007) 158 Тахтап 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [20091.315 ITR 382 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section 2…

M.M. Patel Public Charitable Trust, Solapur vs. PCIT- Central, Pune

In the result, the appeal of the assessee is partly allowed

ITA 1130/PUN/2024[-]Status: DisposedITAT Pune21 Feb 2025
Section 12Section 127Section 12ASection 12A(1)(ac)Section 132Section 143(3)Section 153A

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Тахтап 1/339 ITR 622, Uttaranchal High Court in the case of Welhom Boys' School Society v. CBDT [2006] 285 ITR 74//2007) 158 Тахтап 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [20091.315 ITR 382 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section 2…

M/S Punjab Institute of Medical Sciences, Garha Road, Jalandhar vs. Commissioner of Income Tax Jalandhar and Anr

ITA/271/2014HC Punjab & Haryana04 Dec 2024

Bench: MR. JUSTICE SANJEEV PRAKASH SHARMA,MR. JUSTICE SANJAY VASHISTH

Section 11

…examined the cancellation made with effect from 2004-2005 on the issue relating to retrospectively. He submits that the judgment of Delhi High Court relied upon by the ld. ITAT in Director of Income Tax (Exemption) vs Mool Chand Khairati Ram Trust (2011) 339 ITR 622 (Delhi) was erroneous and the facts of the said case were different from the facts of the present case. It is submitted that in that case the power under Section 12AA (3) of the Act was exercised before the amendment was incorporated i.e. on 30.06.2009 while the amendment was incorporated with effect from 01.06.2010. Therefore, he submits th…

C-Det Explosive Industries Pvt. Ltd, Nagpur vs. D.C.I.T, Circle-2, Nagpur

In the result, the appeal filed by the revenue (ITA/42/2020) is dismissed and the substantial question of law is answered against the revenue

ITA 312/NAG/2019[2014-15]Status: DisposedITAT Nagpur30 Oct 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Rajesh V. LoyaFor Respondent: Shri Vijay Kumar Subrahmanyan
Section 12ASection 143(3)Section 148Section 35Section 35(1)(ii)

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

C-Det Explosive Industries Pvt. Ltd, Nagpur vs. D.C.I.T, Circle-2, Nagpur

In the result, the appeal filed by the revenue (ITA/42/2020) is dismissed and the substantial question of law is answered against the revenue

ITA 311/NAG/2019[2013-14]Status: DisposedITAT Nagpur30 Oct 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Rajesh V. LoyaFor Respondent: Shri Vijay Kumar Subrahmanyan
Section 12ASection 143(3)Section 148Section 35Section 35(1)(ii)

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

C-Det Explosive Industries Pvt.Ltd., Nagpur vs. Dy. Commissioner of Income Tax, Circle-2, Nagpur

In the result, the appeal filed by the revenue (ITA/42/2020) is dismissed and the substantial question of law is answered against the revenue

ITA 310/NAG/2019[2012-13]Status: DisposedITAT Nagpur30 Oct 2023AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Rajesh V. LoyaFor Respondent: Shri Vijay Kumar Subrahmanyan
Section 12ASection 143(3)Section 148Section 35Section 35(1)(ii)

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

M/S.Punjab Institute of Medical Science, Jalandhar vs. Deputy Commissioner of Income Tax, Jalandhar

In the result, the ITA No

ITA 306/ASR/2017[2010-11]Status: DisposedITAT Amritsar31 Jan 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 11Section 12ASection 143(3)Section 148Section 250

…lied by the AR of the assessee also support the case of the assessee, therefore, from A.Y. 2004-05, the cancellation is out of jurisdiction. The Hon’ble Delhi High Court in the case of Director of Income Tax (Exemption) Vs. Mool Chand Khairati Ram Trust (2011)339 ITR 622 (Delhi) has held that power of cancellation of registration obtained U/s 12A came to be incorporated by way of amendment introduced in Section 12AA(3) by the Finance Act, 2010 w.e.f. 1st June, 2010. The Director of the Income Tax was, therefore, no justified in cancelling the registration U/s 12AA(3) w.e.f. December 2002-03 vide his order dated 3…

M/S.Punjab Institute of Medical Science, Jalandhar vs. Deputy Commissioner of Income Tax, Jalandhar

In the result, the ITA No

ITA 305/ASR/2017[2009-10]Status: DisposedITAT Amritsar31 Jan 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 11Section 12ASection 143(3)Section 148Section 250

…lied by the AR of the assessee also support the case of the assessee, therefore, from A.Y. 2004-05, the cancellation is out of jurisdiction. The Hon’ble Delhi High Court in the case of Director of Income Tax (Exemption) Vs. Mool Chand Khairati Ram Trust (2011)339 ITR 622 (Delhi) has held that power of cancellation of registration obtained U/s 12A came to be incorporated by way of amendment introduced in Section 12AA(3) by the Finance Act, 2010 w.e.f. 1st June, 2010. The Director of the Income Tax was, therefore, no justified in cancelling the registration U/s 12AA(3) w.e.f. December 2002-03 vide his order dated 3…

M/S.Punjab Institure of Medical Science, Jalandhar vs. Deputy Commissioner of Income Tax, Jalandhar

In the result, the ITA No

ITA 304/ASR/2017[2008-09]Status: DisposedITAT Amritsar31 Jan 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 11Section 12ASection 143(3)Section 148Section 250

…lied by the AR of the assessee also support the case of the assessee, therefore, from A.Y. 2004-05, the cancellation is out of jurisdiction. The Hon’ble Delhi High Court in the case of Director of Income Tax (Exemption) Vs. Mool Chand Khairati Ram Trust (2011)339 ITR 622 (Delhi) has held that power of cancellation of registration obtained U/s 12A came to be incorporated by way of amendment introduced in Section 12AA(3) by the Finance Act, 2010 w.e.f. 1st June, 2010. The Director of the Income Tax was, therefore, no justified in cancelling the registration U/s 12AA(3) w.e.f. December 2002-03 vide his order dated 3…

M/S. Punjab Institute of Medical Sciences, Jalandhar vs. Deputy Commissioner of Income Tax, Jalandhar

In the result, the ITA No

ITA 303/ASR/2017[2007-08]Status: DisposedITAT Amritsar31 Jan 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 11Section 12ASection 143(3)Section 148Section 250

…lied by the AR of the assessee also support the case of the assessee, therefore, from A.Y. 2004-05, the cancellation is out of jurisdiction. The Hon’ble Delhi High Court in the case of Director of Income Tax (Exemption) Vs. Mool Chand Khairati Ram Trust (2011)339 ITR 622 (Delhi) has held that power of cancellation of registration obtained U/s 12A came to be incorporated by way of amendment introduced in Section 12AA(3) by the Finance Act, 2010 w.e.f. 1st June, 2010. The Director of the Income Tax was, therefore, no justified in cancelling the registration U/s 12AA(3) w.e.f. December 2002-03 vide his order dated 3…

M/S Punjab Institute of Medical Sciences, Jalandhar vs. The Dy Commissioner of Income Tax, Jalandhar

In the result, the ITA No

ITA 581/ASR/2015[2008-09]Status: DisposedITAT Amritsar31 Jan 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 11Section 12ASection 143(3)Section 148Section 250

…lied by the AR of the assessee also support the case of the assessee, therefore, from A.Y. 2004-05, the cancellation is out of jurisdiction. The Hon’ble Delhi High Court in the case of Director of Income Tax (Exemption) Vs. Mool Chand Khairati Ram Trust (2011)339 ITR 622 (Delhi) has held that power of cancellation of registration obtained U/s 12A came to be incorporated by way of amendment introduced in Section 12AA(3) by the Finance Act, 2010 w.e.f. 1st June, 2010. The Director of the Income Tax was, therefore, no justified in cancelling the registration U/s 12AA(3) w.e.f. December 2002-03 vide his order dated 3…

Lord Real Estate Pvt Ltd, Kolkata vs. DCIT, Cir. 10(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 102/KOL/2021[2014-15]Status: DisposedITAT Kolkata10 May 2022AY 2014-15

Bench: Shri Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Ble] I.T.A. No. 102/Kol/2021 Assessment Year: 2014-15 Lord Real Estate Pvt. Ltd..........................................................................................................Appellant 12C, Chakraberia Road (North), Kolkata – 700 020. [Pan: Aaacl4476A] Vs Dcit, Circle-10(1), Kolkata ..................………………………………………..........................Respondent Appearances By: Shri Anil Kochar, Advocate & Shri Aryan Kochar, Advocate Appearing On Behalf Of The Assessee Shri B.S. Anand, Jcit, Sr. Dr Appearing On Behalf Of The Revenue: Date Of Concluding The Hearing : April 27, 2022 Date Of Pronouncing The Order : May 10, 2022 Order Per Sonjoy Sarma, Jm:

For Respondent: Date of concluding the hearing : April 27, 2022
Section 142(1)Section 143(1)Section 143(3)Section 147Section 35(1)(ii)

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

DCIT (E), Circle- 1(1), New Delhi vs. Dlf Qutab Enclave Complex Educational Charitable Trust, New Delhi

In the result, the appeals of the Revenue are

ITA 3370/DEL/2018[2014-15]Status: DisposedITAT Delhi07 Oct 2021AY 2014-15

Bench: Shri Anil Chaturvedi & Shri Sanjay Garg

Section 11Section 12A

…e Finance Act, 2010 with effect from 01.06.2010. This meant that the power to cancel the registration was conferred under section 12AA(3) only with effect fromOl.06.2010. This is exactly what has been held by this court in DIT v. Mool Chand Khairati Ram Trust-339 ITR 622 (Del) This would be clear from the observations to the following effect:- "7. From the conjoint reading of sub-section (1) clause (b) and sub-section (3) of section 12 A A, it would be seen that the cancellation of the registration was provided where the registration was granted under clause (b) of sub-section (1). Further cancellation under sub-…

DCIT (E), Circle- 1(1), New Delhi vs. Dlf Qutab Enclave Complex Educational Charitable Trust, New Delhi

In the result, the appeals of the Revenue are

ITA 3369/DEL/2018[2013-14]Status: DisposedITAT Delhi07 Oct 2021AY 2013-14

Bench: Shri Anil Chaturvedi & Shri Sanjay Garg

Section 11Section 12A

…e Finance Act, 2010 with effect from 01.06.2010. This meant that the power to cancel the registration was conferred under section 12AA(3) only with effect fromOl.06.2010. This is exactly what has been held by this court in DIT v. Mool Chand Khairati Ram Trust-339 ITR 622 (Del) This would be clear from the observations to the following effect:- "7. From the conjoint reading of sub-section (1) clause (b) and sub-section (3) of section 12 A A, it would be seen that the cancellation of the registration was provided where the registration was granted under clause (b) of sub-section (1). Further cancellation under sub-…

Ssl Exports Ltd., Howrah vs. DCIT, Circle - 3(1), Kolkata

In the result this ground of the assessee is allowed

ITA 2670/KOL/2018[2013-14]Status: DisposedITAT Kolkata21 Oct 2020AY 2013-14

Bench: Sri J. Sudhakar Reddy & Sri Aby T. Varkey)

Section 133ASection 250Section 271Section 35

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

Pradip Tondon, Kolkata vs. ACIT, Cir.-62, Kolkata

In the result, the appeal of assessee is allowed

ITA 2315/KOL/2019[2013-14]Status: DisposedITAT Kolkata19 Feb 2020AY 2013-14

Bench: Shri A. T. Varkey, Jm] Assessment Year: 2013-14

Section 35(1)(ii)Section 80G

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

Indradhanush Agencies Pvt. Ltd., Kolkata vs. I.T.O., Ward-8(4), Kolkata

In the result, the appeal of assessee is allowed

ITA 1668/KOL/2019[2014-15]Status: DisposedITAT Kolkata19 Feb 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm] Assessment Year: 2014-15

Section 133ASection 143(1)Section 148Section 35(1)(ii)

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

Ever Shine Jewel House, Kolkata vs. A.C.I.T.Circle-37, Kolkata

Appeals are allowed in above terms

ITA 2546/KOL/2019[2013-14]Status: DisposedITAT Kolkata14 Feb 2020AY 2013-14

Bench: Shri S.S, Godara

Section 133(6)Section 147Section 35(1)(ii)

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

Ever Shine Jewel House, Kolkata vs. A.C.I.T.Circle-37, Kolkata

Appeals are allowed in above terms

ITA 2545/KOL/2019[2012-13]Status: DisposedITAT Kolkata14 Feb 2020AY 2012-13

Bench: Shri S.S, Godara

Section 133(6)Section 147Section 35(1)(ii)

…e but was prospective in nature. 28. The issue involved in this appeal had also come up for consideration before three High Courts, namely, Delhi High Court in the case of DIT (Exemptions) v. Mool Chand Khairati Ram Trust [2011] 11 taxmann.com 42/199 Taxman 1/339 ITR 622, Uttaranchal High Court in the case of Welham Boys' School Society v. CBDT [2006] 285 ITR 74/[2007] 158 Taxman 199 and Allahabad High Court in the case of Oxford Academy for Career Development v. Chief CIT [2009] 315 ITR 382. 29. All the three High Courts after examining the issue, in the light of the object of Section 12A of the Act and Section…

DIT (Exemptions) v. Mool Chand Khairati Ram Trust (339 ITR 622) — Cited in 31 Judgments | BharatTax