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“section 10(23C)”

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

The decision most relied on for section 10(23C) is CIT v. State Bank of Bikaner & Jaipur (43 Taxmann.com 411), cited in 524 judgments on BharatTax.

Leading authorities on section 10(23C)

CIT v. State Bank of Bikaner & Jaipur
43 Taxmann.com 411 · 2014 · High Court
524
citing judgments

Employee contributions to provident fund, ESI, and other welfare funds, if deposited by the due date for furnishing the return of income under Section 139(1), are allowable as a deduction and cannot be disallowed under Section 36(1)(va) read with Section 2(24)(x) or Section 43B, even if deposited after the due date prescribed by the respective welfare Acts.

Escorts Ltd. v. UOI
199 ITR 43 · 1993 · Supreme Court
267
citing judgments

A statute should not be construed to permit double deduction for the same expenditure unless specifically provided by law.

CIT v. Society of the Sisters of St. Anne
146 ITR 28 · 1984 · High Court
195
citing judgments

Depreciation claimed by a charitable trust on its assets is an allowable application of income for computing exemption under Section 11, and this does not constitute a double deduction.

Director of Income-tax (Exemption) v. Framjee Cawasjee Institute
109 CTR 463 · 1993 · High Court
191
citing judgments

A charitable trust is allowed to claim depreciation on its assets for computing its income, even if the capital expenditure incurred on acquiring those assets was treated as an application of income in the year of acquisition.

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.

CIT v. Kasturi & Sons Ltd.
3 SCC 346 · 1999 · Supreme Court
153
citing judgments

Fiscal statutes must be construed strictly and literally. When the language is plain and unambiguous, courts must give effect to it without considering legislative intent or equitable considerations.

Queen’s Educational Society v. CIT
372 ITR 699 · 2015 · Supreme Court
152
citing judgments

An educational institution that generates a surplus does not automatically lose its charitable status or cease to exist solely for educational purposes. This is true if the surplus is reinvested for its educational objectives, and the predominant object test determines if the institution's primary aim is education or profit.

R.B. Jodha Mal Kuthiala v. CIT
82 ITR 570 · 1971 · Supreme Court
131
citing judgments

Tax laws must be interpreted reasonably and in consonance with justice, even though equitable considerations are generally irrelevant in their interpretation.

Judgments citing section 10(23C)

Dy. Commissioner of Income Tax(Exemptions)-2(1), Mumbai vs. Maharashtra Energy Development Agency, Mumbai

In the result, the grounds raised by the

ITA 1260/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Apr 2025AY 2017-18
Section 10Section 11Section 11(1)(d)Section 12ASection 143(3)

fact that exemption u/s 10(23C)(iv) of the Act can be denied for a particular assessment year if the mandate of section 10(23C)(iv) has not been followed by the assessee trust even though the registration continues? 3. Whether on the facts and circumstances of the case ... computing the income at Rs.7,36,56,999/- as under:- “7. Assessee has claimed that it is holding registration under section 10(23C)(iv) and therefore income must be exempt from tax. However, it is observed that the assessee trust is in the activities of carrying of business or profession

Dy. Commissioner of Income Tax(Exemptions)-2(1), Mumbai vs. Maharashtra Energy Development Agency, Mumbai

In the result, the grounds raised by the

ITA 1259/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Apr 2025AY 2016-17
Section 10Section 10(230)(iv)Section 11Section 11(1)(d)Section 12ASection 143(3)

Thus the income from such activities shall not enjoy exemption under proviso to section 10(23)C of the Act. Therefore exemption under section 10(23C)(iv) is not allowed. Under the circumstances and on facts, the alternative claim of exemption under section 10(23C) also fails. Moreover, the objects ... grounds raised by the Revenue pertain to the order of CIT(A) granting the benefit of provisions contained in Section 10(23C) (iv) of the Act to the Assessee. We have considered the rival submission on this issue, perused the material on record and analysed the position

Dy. Commissioner of Income Tax(Exemptions)-2(1), Mumbai vs. Maharashtra Energy Development Agency, Mumbai

In the result, the grounds raised by the

ITA 1258/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Apr 2025AY 2015-16
Section 10Section 10(230)(iv)Section 11Section 11(1)(d)Section 12ASection 143(3)

Thus the income from such activities shall not enjoy exemption under proviso to section 10(23)C of the Act. Therefore exemption under section 10(23C)(iv) is not allowed. Under the circumstances and on facts, the alternative claim of exemption under section 10(23C) also fails. Moreover, the objects ... grounds raised by the Revenue pertain to the order of CIT(A) granting the benefit of provisions contained in Section 10(23C) (iv) of the Act to the Assessee. We have considered the rival submission on this issue, perused the material on record and analysed the position

Satyendranath Bose Educational & Social Welfare Trust, Kolkata vs. Ward 1(3), Exempt, Kolkata

In the result, appeal of the assessee is allowed

ITA 2339/KOL/2024[2018-19]Status: DisposedITAT Kolkata25 Apr 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaआयकर अपील सं/Ita No.2339/Kol/2024 (नििाारण वर्ा / Assessment Year : 2018-2019) Satyendranath Bose Educational Vs Ward-1(3), Exemption, Kolkata & Social Welfare Trust, 19/2/5, Amar Chakraborthy Rd. Ac Road Khagra, Berhampur-742103 Pan No. : Aaots 9288 C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Siddharth Agarwal, Advocate राजस्व की ओर से /Revenue By : Shri Altaf Husssain, Addl.Cit-Sr. Dr सुनवाई की तारीख / Date Of Hearing : 25/02/2025 घोषणा की तारीख/Date Of Pronouncement : 25/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi Dated 24.09.2024, For The Assessment Year 2018-2019 On The Following Grounds Of Appeal :- 1. That The Order Passed By The Ld. Cit (Appeals), Nfac, U/S 250 Confirming The Additions & Disallowances Made By Learned Assessing Officer Is Contrary To The Law & Facts Of The Case. 2. For That On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Erred In Confirming The Action Of Ao Denying The Benefit Of Exemption Claimed U/S 10(23C) (Iiiad) Of The Act. 3. For That On The Facts & In The Circumstances Of The Case, The Lower Authorities Failed To Correctly Appreciate That The Assessee Was Indeed Maintaining & Aiding Education Institutions & It Existed Solely For Educational Purposes Without Any Motive For Profit & Since Its Annual Receipts Did Not Exceed The Limit Of Rs.1 Crores, It Had Rightly Claimed Exemption U/S 10(23C) (Iiiad) Of The Act.

For Appellant: Shri Siddharth Agarwal, AdvocateFor Respondent: Shri Altaf Husssain, Addl.CIT-Sr. DR
Section 10Section 250

since the annual receipt of the assesee was more than Rs.1 crore and, therefore, the benefit of provisions of Section 10(23C)(iiiad) of the Act was not applicable to the assessee. Accordingly, a show cause notice was issued to the assessee which was replied by the assessee by stating

Institute Management Committee Society, Bathinda vs. The Income Tax Officer, Exemption Ward, Amritsar

ITA 571/ASR/2024[2018-19]Status: DisposedITAT Amritsar24 Apr 2025AY 2018-19

Bench: Sh. Udayan Das Gupta & Sh. Krinwant Sahay

Section 10Section 143(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH: AMRITSAR. (HYBRID HEARING) BEFORE SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SH

Sir Syed Educational & Welfare Society, Bhopal vs. Assessment Unit, Income Tax Department, Delhi

Appeal is allowed for statistical purpose

ITA 821/IND/2024[2018-19]Status: DisposedITAT Indore24 Apr 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshisir Syed Educational & Assessment Unit, Social Welfare Society, Income Tax Department, 867, Ankur Complex, Delhi बनाम/ Hb Colony, Koh E Fiza, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aacts0888E Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.04.2025 Date Of Pronouncement 24.04.2025

Section 10Section 142(1)Section 144Section 147Section 148Section 148ASection 250Section 69A

आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND

Dera Sacha Sauda, Sirsa vs. PCIT(Central), Gurgaon

ITA 21/CHANDI/2024[NA]Status: DisposedITAT Chandigarh24 Apr 2025

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 21/Chd/2024 (Under Section 12Aa) M/S Dera Sacha Sauda, Shah Satnam Ji Dham, Shah Satnam Ji Marg, Sirsa. Vs The Pcit (Central), Gurgaon. स्थायी लेखा सं./Pan No: Aaatd8359H अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By : Shri Rakesh Gupta, Advocate & Shri Saksham Aggarwal, C.A. Revenue By : Shri Rohit Sharma, Cit,Dr Date Of Hearing 05.03.2025 Date Of Pronouncement : 25.04.2025 Per Rajpal Yadav, Vp Hybrid Hearing Order The Assessee Is In Appeal Against The Order Of Ld. Pr. Commissioner Of Income Tax, Central, Gurgaon (In Short 'The Pcit') Dated 27.12.2023 Vide Which Registration Granted Under Section 12Aa Of The Act Dated 13.12.2004 Has Been Cancelled W.E.F. 01.04.2016 By Invoking The Provisions Of Section 12Ab(4) Of The Act.

For Appellant: Shri Rakesh Gupta, Advocate andFor Respondent: Shri Rohit Sharma, CIT,DR
Section 11Section 127Section 12ASection 142Section 143(2)Section 143(3)

Income Tax (Exemptions). It shall be pertinent to mention here that although the said judgment has been rendered in the context of section 10(23C)(vi), but by drawing a parallel analogy, the intention of the Hon'ble ITAT Bench is extendable to the provisions of the registration u/s 12AA ... well. This is because the schemes of sections 10(23C)(vi) and 12AA are the same and the words used in section 10(23C)(vi) are the same as in section 12AB(4), i.e. both the Principal Commissioner of Income Tax and the Commissioner of Income Tax (Exemptions) are competent

Shri Vitthal Rukhumai Devalay Trust, Pune vs. CIT(Exemption), Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 430/PUN/2025[-]Status: DisposedITAT Pune24 Apr 2025

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Ajay Kumar Keshari - CIT
Section 12ASection 12A(1)(ac)Section 80G

assessee is neither regularly registered u/s 12AB read with section 12A(1)(ac)(i) /12A(1)(ac)(iii) nor having regular approval under section 10(23C) read with clause (i) / (iii) of first proviso to the said section and the case is not covered under the exclusions provided vide proviso

Shri Vitthal Rukhumai Devalay Trust, Pune vs. CIT(Exemption), Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 429/PUN/2025[-]Status: DisposedITAT Pune24 Apr 2025

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Ajay Kumar Keshari - CIT
Section 12ASection 12A(1)(ac)Section 80G

assessee is neither regularly registered u/s 12AB read with section 12A(1)(ac)(i) /12A(1)(ac)(iii) nor having regular approval under section 10(23C) read with clause (i) / (iii) of first proviso to the said section and the case is not covered under the exclusions provided vide proviso

Prof. Rajendra Singh Shikshan Samiti, Mandsaur vs. DCIT, CPC, Bengaluru and ITO (Exemption), Ujjain

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

ITA 417/IND/2024[2018-19]Status: DisposedITAT Indore23 Apr 2025AY 2018-19

Bench: Sh. Bhagirath Mal Biyani & Sh. Udayan Dasgupta

For Appellant: S/Sh. Apurva Mehta & Rajesh Mehta, ARs
Section 10Section 12ASection 143Section 143(1)Section 250

memorandum of appeal and has disposed of appeal without adjudicating the case on merits. He further submitted that as per the provisions of section 10(23C)(iiiad) of 6 I.T.A. No. 417/Ind/2024 Rajendra Singh Shikshan Samiti v. DCIT the Act, the aggregate annual receipt of each educational institutions ... Vivekanand Society of Education and Research v. CIT and Another, in ITA No.23/2014 dated 29.12.2017 has dealt with the question regarding interpretation of section 10(23C)(iiiad) where the Hon’ble High Court in response to the question whether aggregate annual receipts of the different institutions are to be clubbed

P. Ramnath Sharma Shiksha Swasthya Avam Samaj Kalayan Samiti, Tikamgarh vs. Income Tax Officer Exemption Ward, Gwalior

The appeal stand allowed for statistical purposes

ITA 401/AGR/2024[2020-21]Status: DisposedITAT Agra22 Apr 2025AY 2020-21

Bench: HON’BLE SHRI SATBEER SINGH GODARA (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Abhijeet Shrivastava, Adv.-Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. Sr. DR
Section 10Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL “DB” BENCH, AGRA BEFORE HON’BLE SHRI SATBEER SINGH GODARA, JM AND HON’BLE

Arya Samaj Mandir, Bhilwara vs. CIT(E), Jaipur

In the result, the appeals of the assessee in ITA No

ITA 1015/JPR/2024[2019-20]Status: DisposedITAT Jaipur22 Apr 2025AY 2019-20

Bench: The Date Of Hearing."

For Appellant: Shri Devang Gargieya, Advocate &For Respondent: Smt. Runi Pal, CIT-DR
Section 12ASection 80G

taxmann.com 46 (A.P.) Aurora Educational Society vs. CCIT, relevant paras are reproduced as under: “10. The scope and amplitude of section 10(23C) (vi) of the Income-tax Act, the provisos there under and the rules and forms applicable thereto, which were the subject-matter of examination in New Noble ... wherever registration of trust or charities is obligatory under state or local laws, the concerned trust, society, other institution etc. seeking approval under section 10(23C) should also comply with provisions of such state laws. This would enable the Commissioner or concerned authority to ascertain the genuineness of the trust

Deputy Commissioner of Income Tax, Central Circle, Ballari vs. Ms Al Badar Educational and Charitable Trust, Ballari

In the result, the appeals of the revenue are allowed and the

ITA 1483/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

Section 12ASection 133ASection 143(1)Section 164(2)

observed as under:- “24. Further, the ITAT, on merits, has held that since the assessee is duly registered under Section 12A read with Section 10(23C)(iv) of the Act and the registration is still valid, the assessee is entitled for claiming benefits as per the provisions of Section ... other consideration, irrespective of the nature of use or application, or retention, of the income from such activity. Thus, it is clear that section 10(23C) and section 11 deal with income that are not to be treated as part of total income. Section 10(23C) exempts the income received

Al-Badar Educational and Charitable Trust, Kalaburagi vs. Deputy Commissioner of Income Tax, Central Circle, Bellary

In the result, the appeals of the revenue are allowed and the

ITA 1410/BANG/2024[2016-17]Status: DisposedITAT Bangalore22 Apr 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

Section 12ASection 133ASection 143(1)Section 164(2)

observed as under:- “24. Further, the ITAT, on merits, has held that since the assessee is duly registered under Section 12A read with Section 10(23C)(iv) of the Act and the registration is still valid, the assessee is entitled for claiming benefits as per the provisions of Section ... other consideration, irrespective of the nature of use or application, or retention, of the income from such activity. Thus, it is clear that section 10(23C) and section 11 deal with income that are not to be treated as part of total income. Section 10(23C) exempts the income received

Sri. Vinayaka Education Institution R, Mandya vs. ITO, Exemptions Ward, Mysore

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

ITA 35/BANG/2025[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2017-18

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Subramanian S, JCIT (DR)
Section 10Section 139Section 234ASection 69A

brief are that the assessee is a trust and engaged in the activity of running educational institution. The assessee is claiming exemption under section 10(23C) of the Act. The assessee for the year under consideration filed return under section 139 of the Act as on 31st March 2018 which ... parties and perused the materials available on record. The assessee, a trust engaged in running an educational institution, has claimed exemption under section 10(23C) of the Income Tax Act. The assessment in this case was reopened under section 148 of the Act based on substantial cash deposits amounting

Shree Pa Digamber Jain Sahitya Shodh Sansthan, Bhilwara vs. CIT, Exemption, Jaipur

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

ITA 150/JPR/2025[2025-26]Status: DisposedITAT Jaipur17 Apr 2025AY 2025-26

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sunil Porwal, C.A. (Thru: VC)For Respondent: Shri Arvind Kumar, CIT-DR
Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iv)

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh

Shree Pa Digamber Jain Sahitya Shodh Sansthan, Bhilwara vs. CIT Exemption, Jaipur

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

ITA 149/JPR/2025[2025-26]Status: DisposedITAT Jaipur17 Apr 2025AY 2025-26

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sunil Porwal, C.A. (Thru: VC)For Respondent: Shri Arvind Kumar, CIT-DR
Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iv)

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh

Krantidevta Savitribai Phule Shikshan Sanstha, Kalyan vs. Commissioner of Income Tax-(Exemption), Pune

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

ITA 585/MUM/2025[2023-24]Status: DisposedITAT Mumbai17 Apr 2025AY 2023-24

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhankrantidevta Savitribai Phule Cit(Exemptions), Shikshan Sansthan R. No. 322, 3Rd Floor, Income C/O- Himanshu Gandhi, 16Th Floor, D Vs. Tax Office, Pmt Building, Wing, Trade World Tower, Kamala Shankar Seth Road, Pune, Mill Compound, Lower Parel, Maharashtra-411 037 Mumbai- 400 013 Pan: Aactk4976F (Appellant) (Respondent)

Section 10Section 12A

24/03/2023 26/08/2023 Ack (Rejected) 992236190240323 4 10AB 21/10/2024 Requirement called for 3. The Appellant had filed application in form 10A for registration under section 10(23C) of Income Tax Act, 1961 on 16/03/2023 for which the Krantidevta Savitribai Phule Shikshan Sansthan provisional registration certificate was issued on 24/03/2023. Since ... under form 10AB for regularization of Certificate vide application No CIT Exemption, Pune/2023-24/12AA/11052 in Form 10AB under clause (ii) of first proviso to section 10(23C) of the Act. The said application was rejected on the ground that appellant has not responded to the notices issued

Retired Bank Employees Charitable and Educational Trust, Bhuj vs. CIT (Exemption), Ahmedabad

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

ITA 308/RJT/2024[NA]Status: DisposedITAT Rajkot11 Apr 2025

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.308/Rjt/2024 (िनधा"रण वष" / Assessment Year : -Na-) Retired Bank Employees बनाम/ The Cit (Exemptions) Charitable & Educational Ahmedabad – 380 015 Vs. Trust 2, Sharda Society Bhuj-Kachchh, Bhuj Bhuj – 370 001 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabar 5167 M (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Ms. Chaunauti H. Dholakia, Ld.Ar Revenue By : Shri Sanjay Punglia, Ld. Cit(Dr) सुनवाई की तारीख / Date Of Hearing 03 /04/2025 घोषणा की तारीख /Date Of Pronouncement 11 /04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha: This Appeal By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Exemption), Ahmedabad [Hereinafter Referred To As “Cit(E)”], Dated 30/03/2024, Rejecting The Application For Registration Under Section 12Ab Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

For Appellant: Ms. Chaunauti H. Dholakia, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 10Section 11Section 115TSection 12ASection 12A(1)(ac)Section 2(15)

duly furnished documents apart from documents uploaded along with the application filed and had also never claimed exemption under section 11, 12 or section 10(23C) of the Act. In light of such disclosure, the application was rightly filed under section 12A(1)(ac) of the Act. 5.1. The Ld.Authorized

I Progress Foundation Aurangabad, Aurangabad vs. CIT Exemption, Pune

ITA 855/PUN/2024[Not Applicable]Status: DisposedITAT Pune11 Apr 2025

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1187 & 855/Pun/2024 I Progress Foundation, 22/1, Mayur Complex, N-6, Cidco, Aurangabad-431001 Vs. Pan : Aabai4359L अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Cit (Exemption), Pune प्रत्यर्थी / Respondent Shri Abhay Shastri Shri Amol Khairnar 14-01-2025 11-04-2025 आदेश / Order Per Astha Chandra, Jm : Two Appeals Filed By The Assessee Are Directed Against The Two Separate Order(S) Both Dated 05.03.2024 Of The Ld. Commissioner Of Income Tax (Exemption), Pune [“Cit(E)"] Whereby He Rejected The Application Of The Assessee Filed Before Him In Form No. 10Ab U/S 12A(1)(Ac) (Iii) & Section 80G(5)(Iii) Of The Income Tax Act, 1961 (The "Act") Filed On 30.09.2023. For The Sake Of Convenience Both The Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 12ASection 12A(1)(ac)Section 80G(5)(iii)

assessee is neither regularly registered u/s 12AB read with section 12A(1)(ac)(i) / 12A(1)(ac)(iii) nor having regular approval under section 10(23C) read with clause (i) / (iii) of first proviso to the said section and the case is not covered under the exclusions provided vide proviso