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“application of income”

Judicial DoctrinesDiversion vs ApplicationDiversion vs Application1,603 judgments

The decision most relied on for application of income is Maxopp Investment Ltd. v. CIT (402 ITR 640), cited in 1,596 judgments on BharatTax.

Leading authorities on application of income

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Godrej & Boyce Manufacturing Company Ltd. v. DCIT
394 ITR 449 · 2017 · Supreme Court
683
citing judgments

Expenditure can only be disallowed under Section 14A if the income is exempt and not part of the total income. The Assessing Officer must first record dissatisfaction with the assessee's accounts or computation before proceeding to make a disallowance under Section 14A or applying Rule 8D.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Olari Little Flower Kuries (P.) Ltd. v. UOI
440 ITR 26 · 2022 · High Court
614
citing judgments

The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing application of income

Dayspring Enterprises of India, Secunderabad vs. ITO., Exemption Ward-1(1), Hyderabad

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of our observations given hereinabove

ITA 1261/HYD/2024[2016-17]Status: DisposedITAT Hyderabad29 Oct 2025AY 2016-17
Section 11Section 11(1)Section 11(1)(a)Section 11(2)Section 139(1)Section 143(3)Section 263

dated 23.06.2018 with a direction to the A.O. to examine the issues with reference to shortfall in application of income of the trust for the objects. The assessee challenged the order passed by the Ld. PCIT(E) before the ITAT, Hyderabad, and the ITAT, Hyderabad dismissed the appeal filed ... assessee filed a revised computation of gross receipts, accumulation of income u/s 11(1)(a) and accumulation of income u/s 11(2), and application of income for the objects of the trust as per ITR filed for A.Ys. 2015-16 and 2016-17 and corrected calculation for the A.Ys

Fiitjee Limited., New Delhi vs. ACIT Circle-25(2), New Delhi

The appeals are allowed partly

ITA 334/DEL/2021[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Shri C.S. Agarwal, Sr. Advocate; &For Respondent: Ms Monika Singh, CIT-DR
Section 14ASection 153A

group carried out charitable activities during the year under consideration and, hence, the society was held to have contravened the provisions relating to application of income for charitable purposes and, accordingly, the benefit u/ss 11 and 12 of the Act was denied to the said society and the said assessee ... 334/Del/2021 “9.3 We have heard the rival submission and perused the relevant material on record. The Assessing Officer has examined the claim of application of income by the assessee as under: “5. The assessee has obtained registration u/s 12A of the I.T. Act, 1961. However, for this the assessee

Fiitjee Limited., New Delhi vs. ACIT Circle-25(2), New Delhi

The appeals are allowed partly

ITA 333/DEL/2021[2010-11]Status: DisposedITAT Delhi29 Oct 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Shri C.S. Agarwal, Sr. Advocate; &For Respondent: Ms Monika Singh, CIT-DR
Section 14ASection 153A

group carried out charitable activities during the year under consideration and, hence, the society was held to have contravened the provisions relating to application of income for charitable purposes and, accordingly, the benefit u/ss 11 and 12 of the Act was denied to the said society and the said assessee ... 334/Del/2021 “9.3 We have heard the rival submission and perused the relevant material on record. The Assessing Officer has examined the claim of application of income by the assessee as under: “5. The assessee has obtained registration u/s 12A of the I.T. Act, 1961. However, for this the assessee

Marshal Security Services, Agra vs. Assistant Commissioner of Income Tax, Agra

In the result, this appeal of the assessee is allowed

ITA 131/AGR/2025[2016-17]Status: DisposedITAT Agra28 Oct 2025AY 2016-17

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singh

Section 143(1)Section 143(2)Section 144Section 250

submit that circulars issued by CBDT are binding in nature on assessing officer. These are issued to ensure uniform and proper administration and application of Income Tax Act (UCO Bank Vs. CIT 1999 Tax Pub (DT) 1303(SC).Circulars and Instructions issued by the board on limited scrutiny clearly mentions ... business expense. The Id.AO in its assessment order disallowed the expenses and established that these are not business expenses and is basically application of income. This addition was upheld by Id. CIT (A) in its order. Assessee gave similar submission before AO & Id. CIT (A) which have been countered

Gmm Pfaulder Ltd., Ahmedabad vs. The Pr.CIT, Ahmedabad-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 839/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad28 Oct 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.839/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-21 Gmm Pfaulder Ltd. The Pr.Cit बनाम/ 3Rd Floor, B-Jadav Chambers Ahmedabad-1 V/S. Navrangpura H.O. Ahmedabad – 380 015 Ashram Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aabcg 0563 A (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 09/09/2025 घोषणा की तारीख /Date Of Pronouncement: 28 /10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of Learned Principal Commissioner Of Income-Tax, Ahmedabad-1 [Hereinafter Referred To As “Ld. Pr. Cit” For Short] Dated 07/03/2025 Passed In Exercise Of His Revisionary Jurisdiction Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short] For Assessment Year (Ay) 2020- 21. 2. The Assessee Has Raised The Following Grounds Of Appeal: Gmm Pfaulder Ltd. Vs. Pcit Asst. Year : 2020-21 2

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Sher Singh, CIT-DR
Section 135Section 143(3)Section 144BSection 263Section 32Section 80G

would defeat both the intent of the Companies Act as well as the Income-tax Act, since CSR outlays represent application of income rather than expenditure incurred wholly and exclusively for business purposes. The Pr.CIT thus held that the Assessing Officer erred in allowing deduction under section 80G in respect

Shri Rambag Mandir Tatha Ramchandraji Bhagwan Sansthan, Pandharpur vs. Commissioner of Income Tax (Exemptions), Pune

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

ITA 658/PUN/2025[Not Applicable]Status: DisposedITAT Pune27 Oct 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Dhiraj DandgavalFor Respondent: Shri Amit Bobde
Section 80GSection 80G(5)

assessee, 4 as discussed above, are religious in nature and thus the instrument under which the assessee is constituted provide for application of income other than charitable purposes. 8. Further, the assessee in its reply not furnished any statistical bifurcation of religious expenses and charitable expenses for last three years

Amigos Prasasth Path Social Welfare Society, Kolkata vs. CIT(Exemption), Kolkata

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

ITA 1501/KOL/2025[---]Status: DisposedITAT Kolkata27 Oct 2025

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1500 & 1501/Kol/2025 Amigos Prasasth Path Social Welfare Society.……….……….……….……Appellant 1 Ram Krishna Bagchi Lane, Beadon Street, Battala, Kol- 700006.. [Pan: Aajta7599P] Vs. Cit (Exemption), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Giridhar Dhelia, Advocate, Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 08, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Present Appeals Have Been Preferred By The Assessee Against Separate Orders Both Dated 28.06.2025 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(E)’] Rejecting The Separate Applications Filed In Form 10Ab For Final Approval As Per The Provisions Of Sections 12A(1)(Ac)(Iii) & 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since Both The Appeals Relate To The Same Assessee & Arise From The Final Registration U/S 12A Of The Act Which Is Compulsory For Getting Subsequent Registration U/S 80G Of The Act Which Are Interconnected In Both The Appeals & Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. Ita No.1500/Kol/2025 Is Taken As Lead Case For Narration Of Facts.

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

whether the objects are charitable in nature or whether the trust is genuinely carrying out charitable activities. The genuineness of the activities and application of income may be examined at the time of assessment and not at the stage of registration. We have gone through the judicial pronouncements and find ... denied merely on apprehension that the trust may engage in non-charitable or commercial activities in future. The proper stage for examining the application of income or potential violation of section 13 is during assessment, and not while considering the application for registration. This legal principle stands fortified

Amigos Prasasth Path Social Welfare Society, Kolkata vs. CIT (Exemption), Kolkata

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

ITA 1500/KOL/2025[----]Status: DisposedITAT Kolkata27 Oct 2025

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1500 & 1501/Kol/2025 Amigos Prasasth Path Social Welfare Society.……….……….……….……Appellant 1 Ram Krishna Bagchi Lane, Beadon Street, Battala, Kol- 700006.. [Pan: Aajta7599P] Vs. Cit (Exemption), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Giridhar Dhelia, Advocate, Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 08, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Present Appeals Have Been Preferred By The Assessee Against Separate Orders Both Dated 28.06.2025 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(E)’] Rejecting The Separate Applications Filed In Form 10Ab For Final Approval As Per The Provisions Of Sections 12A(1)(Ac)(Iii) & 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since Both The Appeals Relate To The Same Assessee & Arise From The Final Registration U/S 12A Of The Act Which Is Compulsory For Getting Subsequent Registration U/S 80G Of The Act Which Are Interconnected In Both The Appeals & Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. Ita No.1500/Kol/2025 Is Taken As Lead Case For Narration Of Facts.

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

whether the objects are charitable in nature or whether the trust is genuinely carrying out charitable activities. The genuineness of the activities and application of income may be examined at the time of assessment and not at the stage of registration. We have gone through the judicial pronouncements and find ... denied merely on apprehension that the trust may engage in non-charitable or commercial activities in future. The proper stage for examining the application of income or potential violation of section 13 is during assessment, and not while considering the application for registration. This legal principle stands fortified

Nilesh Kulkarni Foundation, Mumbai vs. Commissioner of Income Tax ( Exemptions), Mumbai

ITA 5184/MUM/2025[2026-27]Status: DisposedITAT Mumbai27 Oct 2025AY 2026-27

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Rajesh AthavleFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 11Section 12ASection 5Section 80GSection 80G(5)(ii)Section 80G(5)(iii)

amend/clarify clauses to remove any ambiguity. 4. The Ld. CIT (Exemptions) failed to appreciate that section 11 of the Act regulates actual application of income and not the mere presence of certain clauses in the trust deed. Without any actual violation, denial of approval is unjustified. 5. The order passed

Grameen Pragati Foundation, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

In the result, assessee's appeal is allowed

ITA 4840/MUM/2025[N.A ]Status: DisposedITAT Mumbai27 Oct 2025

Bench: Shri Pawan Singh & Smt.Renu Jauhri

For Appellant: Shri Rajiv Khandelwal, CAFor Respondent: Shri Swapnil Choudhary- Sr. AR
Section 11Section 12ASection 12A(1)Section 12A(1)(ac)

assessee may be cancelled. We shall now examine as to whether the existence of objects for carrying out activities outside India or actual application of income outside India in accordance with its objects, would fall under any of the categories of "specified violations" listed out in the Explanation ... only if any business or profession is carried on and there is violation as mentioned therein. This clause will not be attracted for application of income for permitted objects outside India. iii) Clause (c) would be attracted when income of trust held for private religious purposes is applied for those

Shamkris Charity Foundation, Mumbai vs. Commissioner of Income Tax Exemption, Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 3394/MUM/2025[2025-26]Status: DisposedITAT Mumbai27 Oct 2025AY 2025-26

Bench: Hon’Ble Justice (Retd.) C V Bhadangms Padmavathy S, Am

For Appellant: Shri Tanzil R. Padvekar, AdvocateFor Respondent: Shri. Pravin Salunkhe, Sr. AR
Section 12ASection 12A(1)(ac)Section 8

satisfied, he can reject the same. This section does not refer to the activities in India or outside India. It refers to application of income for charitable or religious purposes in India as also with direction of order of the Board for application of income as aforesaid outside India. Reading ... relevant criteria for rejecting the application. In absence of order under section 11(1)(a)(c), one cannot seek benefit for application of income for charitable or religious purposes, outside India Therefore, the order dated 24-3-2004 made by the Director of Income-tax (Exemptions), Annexed at page

Care Today Fund, New Delhi vs. ITO Ward Exemption 1(3), Civic Centre New Delhi

In the result, the appeal of assessee is allowed

ITA 5734/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Care Today Fund, Vs. Income Tax Officer, F-26, First Floor, Exemption 1(3), Connaught Place, New Delhi New Delhi-1100 01 Pan :Aaatc3762B (Appellant) (Respondent)

Section 11Section 11(2)Section 11(3)Section 12ASection 142(1)Section 143(2)Section 2(15)Section 250Section 80G(5)(vi)

Rs.18964378/-by ignoring the fact that the donations which are given by donors for the specific purposes are not to be treated as application of income u/s 11(3). 2. That on the facts and circumstances of the instance case learned Assessing Officer has erred in initiating the penalty proceedings

Dy. Commissioner of Income Tax (Exemptions), Circle, Pune, Swargate vs. Maharashtra State Board of Secondary & Higher Secondary Education, Pune

In the result, the appeal of the assessee is allowed

ITA 825/PUN/2025[2022-2023]Status: DisposedITAT Pune24 Oct 2025AY 2022-2023

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2022-23

For Appellant: Shri Piyush BafnaFor Respondent: Shri Ratnakar Bhimrao Shelake
Section 10Section 10(46)Section 143(1)

During the year under consideration the total receipts of the assessee were Rs.1,91,86,33,440/- out of which the total application of income towards the objects of the assessee board were Rs.1,85,94,67,002/- and the assessee board has balance amount of Rs.5

Sameer Desai Foundation, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

In the result, I.T.A. No. 4509/Mum/2025 is allowed and I

ITA 4509/MUM/2025[N.A ]Status: DisposedITAT Mumbai24 Oct 2025

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Dharan Gandhi (virtually appeared) a/w Vinita Nara A/RsFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 11Section 11(1)(a)Section 12ASection 12A(1)(ac)Section 80G

satisfied, he can reject the same. This section does not refer to the activities in India or outside India. It refers to application of income for charitable or religious purposes in India as also with direction or order of the Board for application of income as aforesaid outside India. Reading ... relevant criteria for rejecting the application. In absence of order under section 11(1)(a)(c), one cannot seek benefit for application of income for charitable or religious purposes, outside India. I.T.A. No. 1560/Mum/2025 3 Therefore, the order dated 24-2-2004 made by the Director of Income-tax (Exemptions

Sameer Desai Foundation, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

In the result, I.T.A. No. 4509/Mum/2025 is allowed and I

ITA 4508/MUM/2025[N.A]Status: DisposedITAT Mumbai24 Oct 2025

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Dharan Gandhi (virtually appeared) a/w Vinita Nara A/RsFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 11Section 11(1)(a)Section 12ASection 12A(1)(ac)Section 80G

satisfied, he can reject the same. This section does not refer to the activities in India or outside India. It refers to application of income for charitable or religious purposes in India as also with direction or order of the Board for application of income as aforesaid outside India. Reading ... relevant criteria for rejecting the application. In absence of order under section 11(1)(a)(c), one cannot seek benefit for application of income for charitable or religious purposes, outside India. I.T.A. No. 1560/Mum/2025 3 Therefore, the order dated 24-2-2004 made by the Director of Income-tax (Exemptions

M/S. Vijayanagar Educational Trust, Bengaluru vs. The Commissioner of Income Tax (Exemption), Bengaluru

In the result appeal of the assessee is allowed

ITA 2006/BANG/2019[2019-20]Status: DisposedITAT Bangalore22 Oct 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2019-20

For Appellant: Shri Hariprasad Nayak, CAFor Respondent: Shri Murali Mohan, CIT(DR)(ITAT), Bengaluru
Section 11Section 115TSection 12ASection 13Section 133A

claim for depreciation has been made either in the books of account in respect of the Nelamangala property or by way of application of income under Section 11(1) of the Act . The CIT(E), in the impugned order, has questioned the Appellant's alleged inconsistent stand regarding claim ... application, merely raised an alternative plea for allowance of depreciation in light of the fact that the entire capital expenditure was disallowed as application of income in the assessment proceedings. It is reiterated that no depreciation was, in fact, claimed on any asset during the year in question. The alternative

Masina Hospital Trust, Mumbai vs. Salil Mishra- CIT (Exemptions), Mumbai

ITA 3378/MUM/2025[2026-27]Status: DisposedITAT Mumbai17 Oct 2025AY 2026-27

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 12ASection 13Section 13(3)Section 186(7)Section 80G

above, M the learned CIT(E) failed to appreciate that in terms of the Explanation to section 12AB, it is the application of income to purposes other than the objects, that constitutes a 'specified violation', and not the application of loan. 7. The learned CIT(E) erred in holding that

Masina Hospital Trust, Mumbai vs. CIT-Exemption, Salil Mishra, Mumbai

ITA 3377/MUM/2025[2026-27]Status: DisposedITAT Mumbai17 Oct 2025AY 2026-27

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 12ASection 13Section 13(3)Section 186(7)Section 80G

above, M the learned CIT(E) failed to appreciate that in terms of the Explanation to section 12AB, it is the application of income to purposes other than the objects, that constitutes a 'specified violation', and not the application of loan. 7. The learned CIT(E) erred in holding that

Pramila Katiyar Charitable and Educational Welfare Trust, Noida vs. ITO (Exemptions), Ghaziabad

In the result, assessee’s appeal is allowed for statistical purposes

ITA 4054/DEL/2025[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singhassessment Year: 2018-19

Section 13(2)Section 143(3)Section 250(6)

sustaining the addition made by the Ld. AO of Rs. 85,00,000/- u/s 13(2) of the Act by treating the application of income of appellant trust instead of business advances. 4. On the facts and circumstances of the case, the Ld.AO erred in making the addition without considering

Shree Karadiya Rajput Samaj Baghi, Baghi-Paddhari vs. The Commissioner of Income Tax (Exemption), Ahmedabad

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

ITA 441/AHD/2025[N.A.]Status: DisposedITAT Ahmedabad16 Oct 2025

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokarasstt.Year : - Shree Karadiya Rajput Samaj Baghi, The Cit(Exemption) C/O. Sarda & Sarda (Ca) Vs. Vejalpur Ahmedabad. Sakar 1St Floor Dr. Radha-Krishnan Road Opp: Rajkumar College Rajkot. Pan : Aatts 3326 A (Applicant) (Responent) Assessee By : Shri Vimal Desai, Ar : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 16/10/2025

For Appellant: Shri Vimal Desai, AR
Section 12ASection 12A(1)(ac)Section 2(15)

provisional registration cancelled, having regard to clause (d) of the Explanation to section 12AB(4) which treats as a “specified violation” the application of income for the benefit of any particular religious community or caste. The assessee was also asked to furnish evidence that no expenditure had been incurred