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“Section 11(1)(c)”

Section References (mined)Section 11Section 11(1)(c)64 judgments

The decision most relied on for Section 11(1)(c) is Ashok Pai v. CIT (292 ITR 11), cited in 812 judgments on BharatTax.

Leading authorities on Section 11(1)(c)

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

K.C. Builders & Anr. v. ACIT
265 ITR 562 · 2004 · Supreme Court
241
citing judgments

When the addition made in the assessment order, on the basis of which a penalty for concealment under section 271(1)(c) is levied, is subsequently deleted, the penalty has no basis and must be cancelled.

Indian Molasses Co. Pvt. Ltd. v. CIT
37 ITR 66 · 1959 · Supreme Court
206
citing judgments

Expenditure is defined as money paid out or away, which is gone irretrievably. To be deductible under Section 37(1), expenditure must be wholly and exclusively for business, not capital or personal, and not fall under specific provisions of Sections 30 to 36, often justifiable on grounds of commercial expediency.

CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal
211 ITR 293 · 1995 · High Court
204
citing judgments

A charitable trust can carry forward its excess expenditure from previous years and adjust it against the income of subsequent years, which qualifies as an application of income under Section 11. Additionally, voluntary contributions received for a specific purpose are treated as corpus funds and are not taxable.

CIT v. Rajasthan & Gujarati Charitable Foundation Poona
402 ITR 441 · 2018 · Supreme Court
187
citing judgments

Depreciation is allowable as a deduction even if the expenditure for acquiring the capital asset was treated as application of income for charitable purposes. This does not constitute a double benefit.

Lissie Medical Institutions v. CIT
348 ITR 344 · 2012 · High Court
164
citing judgments

The Kerala High Court held that charitable institutions claiming exemption under Section 11 are not entitled to claim depreciation on assets used for charitable purposes, taking a view contrary to most other High Courts.

CIT v. Maharana of Mewar Charitable Foundation
164 ITR 439 · 1987 · High Court
153
citing judgments

For charitable trusts, the set-off of excess expenditure from prior years against the income of a subsequent year is considered an application of income for charitable purposes. Similarly, the repayment of loans borrowed for legitimate charitable activities is also treated as an application of income.

Income Tax-III, Pune v. Rajasthan & Gujarati Charitable Foundation Poona
89 Taxmann.com 127 · 2018 · Supreme Court
130
citing judgments

The claim of depreciation under Section 32 of the Income Tax Act for assets used by charitable trusts is permissible, affirming the Bombay High Court's view that such a claim does not amount to a 'double benefit'.

Judgments citing Section 11(1)(c)

Chitradurga Zilla Reddy Jana Sangh(R), Chitradurga vs. Income Tax Officer, Ward-1 Exemption, Hubli

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

ITA 1625/BANG/2025[2017-18]Status: DisposedITAT Bangalore05 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Sri Shivanand Kalakeri, D.R
Section 11(1)Section 12ASection 143(1)Section 250

income has arisen. This, according to the learned counsel, was a wrong premise and contrary to the expression of provision contained in section 11(1)(c) read with Explanation and section 11(1)(c) categorically suggests to the contrary, viz., the income has to be applied for charitable or religious

Jhaverbhai Patel Reserch Centre, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

ITA 7359/MUM/2025[N.A ]Status: DisposedITAT Mumbai27 Jan 2026

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

Section 11Section 11(1)Section 12(1)(ac)Section 12ASection 12A(1)(ac)

scholarship to Indian Resident and paid in India, for higher education of higher medical studies outside India, as a violation of provisions of section 11(1) (c) of the Income Tax Act, 1961.” 2. At the outset, the ld. Authorized Representative (AR) on behalf of the assessee, submitted that ... Annushree Ajitkumar for studies in Washington University and St. Louis School of Medicine. As such expenditure is incurred outside India thus provisions of section 11(1)(c) of the Act, are attracted. Therefore, in view of the same, approval order from the Board received by the trust for expenditure incurred

Shila Ashok Shah Foundation, Mumbai vs. CIT Exemptiom, Mumbai

In the result, appeal of the assessee stands allowed

ITA 6764/MUM/2025[2025-26]Status: DisposedITAT Mumbai19 Jan 2026AY 2025-26

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

Section 11Section 11(1)(c)Section 12ASection 2

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

ITA 4527/MUM/2025[N.A ]Status: DisposedITAT Mumbai10 Dec 2025

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Mr. Tarang Mehta,ARFor Respondent: Shri Umashankar Prasad,(CIT-DR)
Section 11Section 12ASection 8Section 80GSection 80G(5)

does not completely rule out exemption to incomes applied outside India for charitable purposes, granting exemption to certain such applications, as 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 ... 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

Mumbai Cricket Association, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

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

ITA 1257/MUM/2025[2024-2025]Status: DisposedITAT Mumbai02 Dec 2025AY 2024-2025

Bench: Shri Sandeep Gosain& Shri Prabhash Shankar

Section 11(1)(c)Section 12ASection 12A(1)(ac)Section 2(15)

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

In the result, appeal of the assessee is allowed

ITA 5038/MUM/2025[2023-24]Status: DisposedITAT Mumbai31 Oct 2025AY 2023-24

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

For Appellant: Shri J. Kala, CAFor Respondent: Shri Virbhadra Mahajan, Sr. DR
Section 11Section 11(2)Section 11(2)(a)Section 11(3)Section 115BSection 12ASection 143(1)

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

ITA 17/MUM/2025[N.A ]Status: DisposedITAT Mumbai31 Oct 2025

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‟).

For Appellant: Mr. Niraj SethFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 11Section 80GSection 80G(5)Section 80G(5)(iii)

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

ITA 16/MUM/2025[N.A]Status: DisposedITAT Mumbai31 Oct 2025

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‟).

For Appellant: Mr. Niraj SethFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 11Section 80GSection 80G(5)Section 80G(5)(iii)

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

ITA 2617/MUM/2025[-]Status: DisposedITAT Mumbai14 Oct 2025

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 11(1)(c)Section 80G

clause 3(B)(2), 3(B)(13), 3(B)(26), 3(B)(27) and 3(B)(31) are in violation of Section 11(1)(c) of the Act as found mentioned in para 3 of the impugned order. It was futher observed by Ld. CIT(E) that the assessee ... passing an order dated February 20, 2025, cancelling the provisional registration under Section 80G of the Act although there was no violation of section 11(1)(c) of the Act. 5. Without prejudice to the above, that on the facts and circumstances of the case

ITO(E) Ward-2 Ahmedabad, Ahmedabad vs. Shree Asandas B Murjani Education Trust, Ahmedabad

In the result, both the appeals of the Revenue are dismissed

ITA 1224/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 1223 & 1224/Ahd/2025 Assessment Year 2019-20

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri R.P. Rastogi, CIT-D.R
Section 11(1)(c)Section 12ASection 142(1)Section 143(2)Section 270A

consequence of mis- reporting of income. This ground does not sustain as it is an appeal to that of denial of the section 11(1)(c) of the Act which was challenged before us in ITA No. 1223/Ahd/2025 and since the registration u/s. 12AA has been granted, there

ITO (Exemptions) Ward-2 Ahmedabad, Ahmedabad vs. Shree Asandas B Murjani Education Trust, Ahmedabad

In the result, both the appeals of the Revenue are dismissed

ITA 1223/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 1223 & 1224/Ahd/2025 Assessment Year 2019-20

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri R.P. Rastogi, CIT-D.R
Section 11(1)(c)Section 12ASection 142(1)Section 143(2)Section 270A

consequence of mis- reporting of income. This ground does not sustain as it is an appeal to that of denial of the section 11(1)(c) of the Act which was challenged before us in ITA No. 1223/Ahd/2025 and since the registration u/s. 12AA has been granted, there

Herd Educational & Medical Research Foundation, Nagpur vs. Income Tax Officer 4(3), Nagpur

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

ITA 323/NAG/2025[2023-24]Status: DisposedITAT Nagpur24 Sept 2025AY 2023-24

Bench: Shri Narender Kumar Choudhryassessment Year: 2023-24

For Appellant: Shri Shikha Loya, Ld. Amicus CuriaeFor Respondent: Shri Surjit Kumar Saha, Ld. Sr. D.R
Section 11Section 11(1)(c)Section 119(2)(b)Section 12ASection 139(4)Section 143Section 143(1)Section 154Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL, NAGPUR BENCH “SMC”, NAGPUR BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER Assessment Year: 2023

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

ITA 2501/MUM/2025[2023-24]Status: DisposedITAT Mumbai22 Sept 2025AY 2023-24

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.

For Appellant: Shri Prashant Ghumare, AdvFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 11Section 11(2)Section 115BSection 12ASection 143Section 143(1)Section 143(1)(a)Section 250

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

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)

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

Sarangpur Talias Pole Punch Trust, Ahmedabad vs. The ITO, Ward-2, Exemption, Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 929/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad16 Sept 2025AY 2023-24

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divetia & Shri Samir Vora, ARsFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 11Section 11(1)Section 11(1)(c)Section 11(2)Section 11(3)Section 115BSection 119(2)(b)Section 143(1)

Rs.2,00,000/- has been utilised beyond the period of 5 years from the F.Y. of accumulation by virtue of amendment in section 11(1)(c) of the Act applicable from Asst. Year 2023-24. For the sake of convenience, a table showing the "pre and" post amended provision ... section 11(1)(c) is appended herewith. Sarangpur Talia’s Pole Punch Trust vs. ITO(E) Asst.Year –2023-24 - 2– The addition of Rs.2,00,000/- ought not to have been made by virtue of amended section 11(1) (c) of the Act as it was impossible to implement

Jinseva Foundation, Mumbai vs. CIT (Exemption), Mumbai

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

ITA 3532/MUM/2025[2025-2026]Status: DisposedITAT Mumbai29 Aug 2025AY 2025-2026

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

For Appellant: Mr. Margav ShuklaFor Respondent: Mr. Vivek Perampurna, CIT-DR
Section 11Section 12ASection 8

does not completely rule out exemption to incomes applied outside India for charitable purposes, granting exemption to certain such applications, as 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 ... 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

Jinseva Foundation, Mumbai vs. CIT (Exemption), Mumbai

In the result, both the appe

ITA 3531/MUM/2025[2025-2026]Status: DisposedITAT Mumbai29 Aug 2025AY 2025-2026

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

For Appellant: Mr. Margav Shukla
Section 11Section 12A

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

ITA 3396/MUM/2025[2023-24]Status: DisposedITAT Mumbai28 Aug 2025AY 2023-24

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)

For Appellant: Shri Haridas Bhat, CAFor Respondent: Shri Annavaram Kosuri, CIT DR
Section 10Section 11Section 11(2)Section 11(2)(a)Section 115BSection 12ASection 143Section 143(1)Section 143(3)

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

ITA 3011/MUM/2025[2023-24]Status: DisposedITAT Mumbai28 Aug 2025AY 2023-24

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:

For Appellant: Shri Haridas Bhat, CAFor Respondent: Shri Aditya M. Rai, Sr. DR
Section 10Section 11Section 11(2)Section 11(2)(a)Section 11(3)Section 115Section 115BSection 12ASection 143Section 143(1)

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

Noida Golf Course Society, Noida vs. JCIT, Noida

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

ITA 2053/DEL/2015[2010-11]Status: DisposedITAT Delhi08 Aug 2025AY 2010-11

Bench: Shri M Balaganesh

For Appellant: Shri Rajiv Sharma, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 11(1)Section 11(1)(c)Section 12ASection 142(1)Section 143(1)Section 143(2)Section 2(15)Section 250

well as the learned Commissioner of Income Tax (Appeals) erred in law and on facts in not allowing the Appellant exemption under section 11(1)(c) of L.T. Act while the Golf Course was registered under section 12AA by the Learned Commissioner of Income Tax, Meerut. 2. BECAUSE