“Section 11(1)(c)”

JHAVERBHAI PATEL RESERCH CENTRE ,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

view of the same, approval order\nfrom the Board received by the trust for expenditure incurred outside India, as\nmandated by proviso to section 11(1)(c) of the Act was called for from the\napplicant vide DIN & Notice No. ITBA/EXM/F/EXM43/2025-26/1080944436(1)\ndated 19.09.2025.\n4.3 In response, the applicant filed ... Annushree Ajitkumar, while the donation was initially made to her by the\nTrust. Therefore, in accordance with the provisions of Section 11(1)(c) of the\nIncome Tax Act, the Trust was required to obtain prior approval from the Board\nbefore incurring such expenditure outside India.\nIn light

SHILA ASHOK SHAH FOUNDATION,MUMBAI vs. CIT EXEMPTIOM, MUMBAI

In the result, appeal of the assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

registration under Section 12AB of the Act, giving the reason that the trust had applied the income outside India, in violation of Section 11(1)(c) of the Act. Whereas, the appellant trust had given an educational grant of 74,00,000 (Rupees Four Lakh only) in Indian currency ... India, the fact that the final execution of such purpose takes place outside India will not constitute a violation of the provisions of Section 11(1)(c) of the Act and will not be treated as application of fund outside India. 5. The fact and circumstances of the case supra

RITHWIK FOUNDATION FOR PERFORMING ARTS ,MUMBAI vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN, JUDICIAL MEMBER\n&\nSHRI PRABHASH SHANKAR (Accountant Member)

does not completely rule out exemption to incomes applied\noutside India for charitable purposes, granting exemption to certain such applications, as\nmentioned in section 11(1)(c), subject to being approved by the Board.\n\n12. As is evident from the above, in the scheme of the Act, incomes applied

MUMBAI CRICKET ASSOCIATION,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), MUMBAI, MUMBAI

In the result, appeal filed by the appellant stands allowed for statistical purposes

Bench: Shri Sandeep Gosain& Shri Prabhash Shankar

Mumbai Cricket Association, Mumbai. 3.The learned Commissioner of Income Tax (Exemptions) erred in facts and in law in holding that provisions of section 11(1)(c) of the Act are violated without appreciating that 'arranging tours outside India' does not amount to application of income for purposes outside India ... objects, included an object permitting the Appellant to organize tours of its cricketers outside India, which was treated as in violation of section 11(1)(c) of the Act (b) The streams of income earned by the Appellant reflected incomes which in the opinion of the Commissioner of Income

SHRI CHINTAMANI PARSHWANATH SHWETAMBAR MURTIPUJAK JAIN SANGH,MUMBAI vs. EXEM. WARD 2(3), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

utilised in financial year 2022-23 being the 6th financial year from the financial year of accumulation as per the condition of section 11(1)(c) which existed prior to the amendment. Though the accumulated unutilised income of Rs. 37,00,000/- as at the end of 5th financial year

R. MANGALDAS CHARITABLE TRUST ,MUMBAI vs. CIT(EXEMPTION), MUMBAI

In the result, the appeal of assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyr. Mangaldas Charitable Trust, Cit (Exemptions), A-82, Vishnu Baug, Room No. 601, 137, S.V. Road, Vs. 6Th Floor, Andheri (W), Cumballa Hills, Mumbai-400058. Mtnl Te Building, Pedder Road, Pan : Aaatr0606H Dr.Gopalrao Deshmukh Marg, Cumballa Hill, Mumbai-400026. (Appellant) (Respondent) For Assessee : Mr. Niraj Seth For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 01-10-2025 Date Of Pronouncement : 31-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Exemptions)-Mumbai [„Ld.Cit(E)‟], Dated 19-11-2024, Rejecting The Assessee‟S Application Moved U/S. 80G(5)(Iii) Of The Income Tax Act, 1961 („The Act‟).

would otherwise be entitled to under law. 14. Further as rightly pointed out by the Ld.Counsel for the assessee, the provisions of section 11(1)(c) of the Act, which the Ld.CIT(E) has relied upon for holding that only activities carried out in India will qualify as charitable ... apart from the money being spent in India even the purpose must be carried out in India. The section itself contradicts this contention. Section 11(1)(c)(ii) provides that income applied to such purposes outside India is exempt in the case of trust created before 1-4-1952 subject

MITRA PARIVAR ,MUMBAI vs. CIT(EXEMPTION), MUMBAI

In the result, the appeal of assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharymitra Parivar, Cit (Exemptions), 301, Maganlal Kala, Room No. 601, Gulmohar Road No.1, Vs. 6Th Floor, Jvpd Extn. Cumballa Hills, Andheri (West), Mtnl Te Building, Pedder Road, Mumbai-400049. Dr.Gopalrao Deshmukh Marg, Pan : Aaatm5059M Cumballa Hill, Mumbai-400026. (Appellant) (Respondent) For Assessee : Mr. Niraj Seth For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 01-10-2025 Date Of Pronouncement : 31-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Exemptions)-Mumbai [„Ld.Cit(E)‟], Dated 19-11-2024, Rejecting The Assessee‟S Application Moved U/S. 80G(5)(Iii) Of The Income Tax Act, 1961 („The Act‟).

would otherwise be entitled to under law. 14. Further as rightly pointed out by the Ld.Counsel for the assessee, the provisions of section 11(1)(c) of the Act, which the Ld.CIT(E) has relied upon for holding that only activities carried out in India will qualify as charitable ... apart from the money being spent in India even the purpose must be carried out in India. The section itself contradicts this contention. Section 11(1)(c)(ii) provides that income applied to such purposes outside India is exempt in the case of trust created before 1-4-1952 subject

MOHANJI BHARAT WELFARE FOUNDATION,MUMBAI vs. CIT (EXEMPTION), MUMBAI

In the result, the appeal filed by the assessee is allowed for\nstatistical purposes in above terms

clause 3(B)(2), 3(B)(13),\n3(B)(26), 3(B)(27) and 3(B)(31) are in violation of Section 11(1)(c) of the\nAct as found mentioned in para 3 of the impugned order. It was futher\nobserved by Ld. CIT(E) that the assessee ... passing an order dated\nFebruary 20, 2025, cancelling the provisional registration under Section\n80G of the Act although there was no violation of section 11(1)(c) of the\nAct.\n5. Without prejudice to the above, that on the facts and circumstances of\nthe case

THE BOMBAY SOCIETY OF THE FRANCISCAN CLARIST SISTERS OF THE MOST BLESSED SACRAMENT,MUMBAI vs. ITO EXEM WARD 2(4), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Smt. Renu Jauhriआयकर अपील सुं./Ita No.2501/Mum/2025 (धििाारण वर्ा / Assessment Year: 2023-2024) The Bombay Society Of V/S. Income Tax Officer, The Franciscan Clarist बिाम Ward 2(4), Mumbai Sisters Of The Most 6Th Floor, Mtnl Tel. Ex. Blessed Sacrament Building, Cumballa Hills, St. Anthony’S Home For The Pedder Road, Mumbai Aged, 51, Chapel Road, 400026 Bandra (West), Mumbai 400050 स्थायी लेखा सुं./जीआइआर सुं./Pan/Gir No: Aaatt0738Q Appellant/अपीलाथी .. Respondent/प्रधिवादी धििााररिी की ओर से /Assessee By: Shri Prashant Ghumare, Adv. राजस्व की ओर से /Revenue By: Shri Bhagirath Ramawat, Sr. Dr (Virtually Present) स िवाई की िारीख / Date Of Hearing 03.09.2025 घोर्णा की िारीख/Date Of Pronouncement 22.09.2025 आदेश / O R D E R Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The Addl/Jcit (A)-2 Delhi, [Cit(A)] Dated 28.02.2025 Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For Assessment Year 2023-2024. 2. The Assessee Has Raised The Following Grounds In This Appeal.

year 2022-23 being in the sixth financial year from the financial year of accumulation i.e. 2016-17 as per the condition of section 11(1)(c) before amendment. Though the accumulated unutilised income of Rs. 24,34,928/- as at the end of fifth financial year was spent

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

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

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

after detailed examination of the facts and correct application of the law. The Ld. DR argued that the assessee is not covered by section 11(1)(c) and hence expenses outside India are not permissible. The Ld. DR also stated that the benefit of charity should be available to public ... fees, subscriptions, and training of educators. all for the purpose of imparting education within India. Reliance placed by the Ld. CIT(E) on Section 11(1)(c) of the Act is misplaced, since the assessee claims exemption u/s 11(1)(a) of the Act. The Ld. DR specifically relied

JINSEVA FOUNDATION,MUMBAI vs. CIT (EXEMPTION), MUMBAI

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

does not completely rule out exemption to\nincomes applied outside India for charitable purposes, granting exemption to certain such\napplications, as mentioned in section 11(1)(c), subject to being approved by the Board.\n12. As is evident from the above, in the scheme of the Act, incomes applied outside

JINSEVA FOUNDATION,MUMBAI vs. CIT (EXEMPTION), MUMBAI

In the result, both the appe

Bench: Ms. Kavitha Rajagopal () & Smt. Renu Jauhri ()

outside India for charitable purposes, granting exemption to certain such a for charitable purposes, granting exemption to certain such applications, as mentioned in section 11(1)(c), subject to being approved by the Board. applications, as mentioned in section 11(1)(c), subject to being approved by the Board. applications ... mentioned in section 11(1)(c), subject to being approved by the Board. 12. As is evident from the above, in the scheme of the Act, incomes applied outside India 12. As is evident from the above, in the scheme of the Act, incomes applied outside India

ROMAN CATHOLIC CHURCH OF ST. PAUL,MUMBAI vs. ITO EXEM.WARD 2(2), MUMBAI

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

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2023-24 Roman Catholic Church Of St. Income Tax Officer (Exem.), Paul Ward 2(2) St Paul Church, Vs. Dr. Ambedkar Road, Dadar, Mumbai - 400014 (Pan : Aaatr2742L) (Appellant) (Respondent)

utilised in financial year 2022-23 being the 6th financial year from the financial year of accumulation as per the condition of section 11(1)(c) which existed prior to the amendment. Though the accumulated unutilised income of Rs. 37,00,000/- as at the end of 5th financial year

ST. ANTHONYS CHURCH,MUMBAI vs. ITO WARD 2(3), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2023-24 St. Anthony’S Church Ito Exem, Ward 2(3), Mumbai St. Anthony’S Church, Marve Road, Malwani, Vs. Malad, Mumbai – 400094. (Pan: Aacts6737L) (Appellant) (Respondent) Present For:

utilised in financial year 2022-23, being the 6th financial year from the financial year of accumulation, as per the condition of section 11(1)(c) which existed prior to the amendment. 3.3. Though the accumulated unutilised income of Rs.15,79,570/- as at the end of 5th financial year