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DeductionsSection 10(23C)Section 10(23C)1,207 judgments

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1424/JPR/2025[2022-23]Status: DisposedITAT Jaipur23 Mar 2026AY 2022-23
Section 10Section 250

appeal before the Hon'ble Rajasthan High Court which is pending on the\nsubstantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)?\n3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without\nconsidering the statutory amendment namely, the Explanation inserted ... w.e.f. 01.04.2015\nto section 10(23C)(iiiab), read with Rule 2BBB of the Income-tax Rules, 1962 which\nclarifies that \"substantially financed\" means receipt of Government grant (and not mere\nrevenue from commercial activity), and in doing so rendered a perverse finding contrary\nto legislative intent?\n4. Whether

DCIT, EXEMPTION CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1423/JPR/2025[2012-13]Status: DisposedITAT Jaipur23 Mar 2026AY 2012-13

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1339/JPR/2025[2010-11]Status: DisposedITAT Jaipur23 Mar 2026AY 2010-11

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1338/JPR/2025[2011-12]Status: DisposedITAT Jaipur23 Mar 2026AY 2011-12

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1337/JPR/2025[2014-15]Status: DisposedITAT Jaipur23 Mar 2026AY 2014-15

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1336/JPR/2025[2015-16]Status: DisposedITAT Jaipur23 Mar 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1335/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Mar 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1334/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Mar 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

The appeals of the revenue are dismissed

ITA 1333/JPR/2025[2017-18]Status: DisposedITAT Jaipur23 Mar 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOOK, JAIPUR

The appeals of the revenue are dismissed

ITA 1332/JPR/2025[2018-19]Status: DisposedITAT Jaipur23 Mar 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

Section 10Section 250

finance from the Government of Rajasthan? 2. Whether, on the facts and in law, the Ld. CIT(A) erred in granting exemption under section 10(23C)(iiiab) of the Income-tax Act, 1961 by relying solely on the order of the Hon'ble ITAT, Jaipur in assessee's own case ... appeal before the Hon'ble Rajasthan High Court which is pending on the substantial question of law regarding assessee's eligibility under section 10(23C)(iiiab)? 3. Whether the Ld. CIT(A) was justified in applying the ITAT's earlier order without considering the statutory amendment namely, the Explanation inserted

HAMDARD LABORATORIES INIDA,DELHI vs. DCIT CIRCLE(E) 1(1), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 8826/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2023-24] Hamdard Laboratories India, Dcit, Circle(Exempt), Hamdard Building, 2A/3, Asaf Civic Centre, New Delhi Ali Road, New Delhi-110002 Vs Pan-Aaath0842H Appellant Respondent Appellant/Assessee By Shri S.R Mehta, Ca Respondent/Revenue By Shri Ajay Kumar Arora, Sr. Date Of Hearing 19.03.2026 Date Of Pronouncement 20.03.2026 Order Per Amitabh Shukla, Am

Section 10Section 139(5)Section 143(1)Section 143(3)Section 250

additions u/s 143(1) without an opportunity of being heard, there was no need to have given directions for consideration of provisions of section 10(23C)(iv) of the Act in its case. It was further pleaded that the impugned directions of ld. CIT(A) given vide its order dated ... First Appellate Authority that he had issued directions for re-examination of assessee’s case in the light of provisions of section 10(23C)(iv) of the Act. We have also noted from pages 26 to 36 of the order of the ld. AO dated 26.03.2025 that he had considered

GITA EDUCATIONAL TRUST,DELHI vs. AO WARD EXEMPTION (2), DELHI

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

ITA 5194/DEL/2025[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmana.Yr. : 2018-19 Gita Educational Trust, Vs. Ao Ward Exemption (2), 278, Kailash Hills, Kailash Civic Centre, New Delhi Colony, Delhi – 110 028 (Pan: Aaatg3902B)

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 10Section 11Section 12ASection 143(1)

computation of income. Due to one error at the time of filing software instead of taking section 12A wrongly took it as section 10(23C). The department denied the deduction u/s. 11 and computed the total receipt as income. Against the aforesaid action, the Assessee preferred the appeal before ... assessee by disallowing the exemption of Rs. 8,25,12,474/- claimed by the assessee on the following reasons: (i) Assessee approved under section 10(23C) (iv) or 10(23C)(v) or 10(23C)(vi) or 10(23C) (via) and claiming exemptions under Sr. No. 4i to 4viii in Part

B R MORDEM SCHOOL SAMITI,PAURI vs. I T O, EXEMPTION WARD DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 27/DDN/2026[2016-17]Status: DisposedITAT Dehradun13 Mar 2026AY 2016-17
Section 10Section 12ASection 143(3)Section 148Section 250

Charitable Trust vs ITO order dated\n06.04.2023 wherein it is held that the annual receipts should only\nbe considered for the purpose of section 10(23C)(iiiad) and the corpus\ndonation received with specific direction to develop infrastructure\nfacilities is a capital receipts. Therefore, Ld.AR requested that the\nassessee ... Guard File\nSr.P.S/ASSISTANT REGISTRAR\nITAT, NEW DELHI\n(Dehradun Circuit Bench, Dehradun)\n", "summary": { "facts": "The assessee, an educational institution, claimed exemption under section 10(23C)(iiiad). The AO included voluntary donations for the building fund in the gross receipts, exceeding the threshold limit and denying exemption. The assessee contended

MEHAR PALLIATIVE CARE TRUST,AHILYANAGAR vs. CIT(E) , NASHIK

In the result, the appeal of the assessee is allowed

ITA 217/PUN/2026[2020-21]Status: DisposedITAT Pune13 Mar 2026AY 2020-21

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.217/Pun/2026 Assessment Year : 2020-21 Meher Palliative Care Trust, Vs. Cit (Exemption), Plot No.1, Gat 515/1/1, Nashik Behind Stone Terrace Cond. Post Meherabad Arangaon, Tal Dist. Ahilyanagar – 414001 Maharashtra Pan : Aaetm1969Q Appellant Respondent

For Appellant: Shri Prasad BhandariFor Respondent: Shri Dayanand Jawalikar
Section 10Section 10(23)(iiiae)Section 143(2)Section 143(3)

iiiae) of the Act and there is no specific requirement for applying for registration of such institution as per the first proviso to section 10(23C) of the Act. So far as the genuineness of the accounts are concerned, I find that the assessee has maintained regular books of accounts

ROONGTA WELFARE FOUNDATION,SURAT vs. CIT(EXEMPTION),AHEMDABAD, AHEMDABAD

The appeal of the assessee is allowed for statistical purposes

ITA 228/AHD/2026[NA]Status: DisposedITAT Ahmedabad12 Mar 2026

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Alpesh Parmar, CIT DR
Section 10Section 12ASection 80GSection 80G(5)Section 80G(5)(ii)Section 80G(5)(iii)

that the assessee did not hold any valid registration either in Form No. 10AD or Form No. 10AC under section 12A/12AB or under section 10(23C) at the time of filing the present application in Form No. 10AB. On the basis of the above observations, the Ld. CIT(Exemptions) held

THE BOMBAY HINDU BURNING AND BURIAL GROUNDS COMMITTEE,MUMBAI vs. ITO EXE WARD 2(4), MUMBAI

In the result, the grounds of appeal raised by the assessee are allowed for statistical purpose

ITA 9324/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Mar 2026AY 2018-19

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

Section 10Section 11Section 12ASection 143(1)Section 143(1)(a)Section 154Section 254(1)

Burial Grounds Committee years. While filing return for A.Y. 2018-19, due to inadvertence, the status of the trust was shown as section 10(23C) instead of 12AA. The return was processed by CPC and intimation order dated 10/11/2019 was issued, wherein the deduction ... assessee trust is more than its gross receipt. The only basis for not allowing deduction of expenses is wrong copying/mentioning the provision of Section 10(23C) instead of 12AA. The assessee filed an application under section 154 before the CPC in December, 2019. Such application was dismissed/rejected

RAI SAHAB BHAIYALAL DUBEY EDUCATIONAL AND MEDICAL CHARITABLE TRUST,JABALPUR vs. INCOME TAX OFFICER (EXEMPTION), JABALPUR

In the result, the appeal is partly allowed for statistical purposes

ITA 186/JAB/2024[2020-21]Status: DisposedITAT Jabalpur10 Mar 2026AY 2020-21

Bench: Shri Anadee Nath Misshra

Section 11Section 11(2)Section 11ASection 12ASection 143(1)

Incomes which do not form part of total income.”. Both sections 10 and 11 are included within this chapter. Moreover, first line of section 10(23C) starts with the words – “any income received by any person on behalf of….”. Intention of the legislature is clear. If the conditions

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

notice u/s. 148 of the Act. Further, the appellant has claimed that the trust is exempt from filing of Income tax return under section 10(23C) (iiiab) and 10(23C)(iiiad) of the Act. The appellant has, however, claimed exemption u/s.11 of the Act where the appellant filed return

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

notice u/s. 148 of the Act. Further, the appellant has claimed that the trust is exempt from filing of Income tax return under section 10(23C) (iiiab) and 10(23C)(iiiad) of the Act. The appellant has, however, claimed exemption u/s.11 of the Act where the appellant filed return

CHIMANLAL MODI CHARITABLE TRUST,MEHSANA vs. CIT (EXEMPTION), AHMEDABAD, AHMEDABAD

In the result, the appeal filed by the assessee in ITA No

ITA 2521/AHD/2025[NOT APPLICABLE]Status: DisposedITAT Ahmedabad10 Mar 2026

Bench: Six Months From The Date Of Commencement Of The Activities, Which Was Further Extended By Cbdt Circular No. 7 Of 2024 Up To 30-06- 2024 But The Assessee Trust Had Not Filed Any Reason For Delay In Filing Such Application. Therefore Ld. Cit(E) Denied The Registration By Observing That The Application Is Filed Belatedly.

Section 12ASection 12A(1)(ac)Section 80G

registration became inoperative under Section Before expiry of the approved 10A Provisional/Fresh (via) 11(7) (due to 10(23C) approval) and period under Section 10(23C) or registration now applies again under Section immediately thereafter 12A 6.3. As per clause (iii) of section

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