← All Phrases

“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

Adv. Chandansinh Solanki Educational Trust, Virar vs. ITO, Bengaluru

In the result, the appeal of the assessee-trust is allowed

ITA 6378/MUM/2025[2020-21]Status: DisposedITAT Mumbai29 Jan 2026AY 2020-21

Bench: The First Appellate Authority Came To Be Dismissed Ex Parte Without Affording A Meaningful Opportunity Of Being Heard; & Secondly, That The Lower Authorities Erred In Upholding The Adjustments Made Under Section 143(1), Namely: (A) Denial Of Deduction Under Section 11(1)(A) In Respect Of Actual Revenue Expenditure Of ₹ 89,77,260 Debited To The Income & Expenditure Account; & (B) Disallowance Of The Claim For Statutory Accumulation Of Income Under Section 11(1)(A) To The Extent Of ₹ 11,65,005, Thereby Treating The Gross Receipts Of ₹ 1,01,42,265 As Taxable Income.

Section 11Section 11(1)(a)Section 12ASection 143(1)Section 2Section 250

Form No. 10B had not been filed within the prescribed time. As a corollary thereto, the CPC disallowed the deduction claimed for actual application of income amounting to ₹ 89,77,260 and also denied the benefit of statutory accumulation of income to the extent of 15 per cent of gross ... timing requirement for filing Form No. 10B, without disputing either the charitable nature of the objects of the Trust or the factum of application of income for charitable purposes. 6. The learned counsel for the assessee submitted that the due date of filing the return of income

Jainacharya Devendra Muni Shikshan and Chikitsa Shodh Sansthan, Udaipur vs. ADIT, CPC, Bengaluru / ITO, Exemption Ward, Udaipur

The appeal is allowed for statistical purpose

ITA 256/JODH/2025[2016-17]Status: DisposedITAT Jodhpur28 Jan 2026AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blejainacharya Devendra Muni Adit, Cpc, Bengaluru/ Ito Shikshan & Chikitsa Shodh Exemption Ward Sansthan Udaipur - 313001 N H 8-1 (4) Bhuwana Udaipur (Raj) - 313001 Pan No. Aaatj 5263 G Assessee By Shri Yogesh Pokharna, C.A. (Physical) Shri K.C. Meena, Addl. Cit-Dr (Virtual) Revenue By Date Of Hearing 13.01.2026. Date Of Pronouncement 28.01.2026. Order Dr. Mitha Lal Meena, A.M.: The Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax, Appeal, Addl/Jcit (A)-1 Visakhapatnam [Hereinafter Referred To As “The Jcit Appeal”] Dated 05.03.2025 With Respect To Assessment Year 2016-17 Challenging Therein Disallowance Of Capital Expenditure Amounting To Rs. 24,75,863/- In Corpus Fund Of Rs. 6,09,448/- Without Appreciating The Merits Of The Case.

Section 11(2)Section 139(1)Section 139(4)Section 250

holding that AO was justified in rejecting claim of accumulation of fund of Rs. 21,75,000/- to be deemed application of income and treated the same as the income of the Asst. Year: 2016-17 3 assessee. Further, the Ld. CIT(A) has discussed that there was a difference

Shree Tarak Guru Jain Granthalya, Udaipur vs. DCIT, CPC, Bengaluru / ITO (Exemption), Udaipur

ITA 22/JODH/2023[2019-20]Status: DisposedITAT Jodhpur28 Jan 2026AY 2019-20

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Ble

Section 1Section 11Section 11(1)Section 11(2)Section 12ASection 12A(1)(ba)Section 13(9)Section 139(5)Section 139(9)Section 143(1)(A)

that in view of the limited powers, the AO and the CPC has no right to deny the benefits of set apart or application of income as the same requires interpretation of law with the proceedings as provided u/s 11 of the Income Tax Act. He has objected ... observation that Section 13(9) introduces with effect from Assessment Year 2016-17 that benefit of application of income u/s 11 cannot be allowed where return of income is filed after due date. He submitted by strict interpretation of this Section 139(5) which allows belated filing of return will

Shree Tarak Guru Jain Granthalya, Udaipur vs. DCIT, CPC, Bengaluru / ITO (Exemption), Udaipur

ITA 21/JODH/2023[2017-18]Status: DisposedITAT Jodhpur28 Jan 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Ble

Section 1Section 11Section 11(1)Section 11(2)Section 12ASection 12A(1)(ba)Section 13(9)Section 139(5)Section 139(9)Section 143(1)(A)

that in view of the limited powers, the AO and the CPC has no right to deny the benefits of set apart or application of income as the same requires interpretation of law with the proceedings as provided u/s 11 of the Income Tax Act. He has objected ... observation that Section 13(9) introduces with effect from Assessment Year 2016-17 that benefit of application of income u/s 11 cannot be allowed where return of income is filed after due date. He submitted by strict interpretation of this Section 139(5) which allows belated filing of return will

Bansilal Ramnath Agarwal Charitable Trust, Pune vs. CIT (Exemption), Pune

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

ITA 1357/PUN/2025[2020-21]Status: DisposedITAT Pune28 Jan 2026AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 11Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 2(15)Section 263

excessive payments to the specified persons, and ought not to have disturbed entire transaction with the specified persons. Appellant contends that, disallowance of "Application of income" ought to be confined to alleged excessive/violative portion of the payments to specified persons. 7. Appellant craves leave to add/modify/delete/amend

Shri Namo Narain Educational and Chairitable Trust, Bareilly vs. Income Tax Officer, Exemption, Bareilly

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

ITA 272/LKW/2025[2023-24]Status: DisposedITAT Lucknow27 Jan 2026AY 2023-24

Bench: Shri Anadee Nath Misshra

Section 143(1)

Addl./JCIT(A)-3 has erred in law and on facts in disallowing the repayment of loan during the year – Rs.87,650/- as application of income.” (C) At the time of hearing before us, there was no representation from the assessee’s side. In the absence of any representation from

M/S. Raya Naik Memorial Gowshala Trust, Kajubag Karwar vs. Commissioner of Income Tax (Exemptions) Bangalore, Unity Building Annexe, Mission Road, Bangalore

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

ITA 1920/BANG/2025[2024-25]Status: DisposedITAT Bangalore27 Jan 2026AY 2024-25

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

For Appellant: Shri Siddesh Gaddi, CAFor Respondent: Shri Muthu Shankar, CIT (DR)
Section 12ASection 12A(1)(ac)Section 2(15)

activities. The provision does not empower the Commissioner to conduct a roving or Page 7 of 11 detailed enquiry into the application of income, adequacy of expenditure, accumulation of funds, or the source and creditworthiness of donations. In so far as the objection regarding mismatch in the number of cows ... larger projects has not been found to be false or untrue. 10.6 Furthermore, the law prescribes that any violation regarding the actual application of income can be examined during the assessment proceedings, and appropriate action under the relevant sections read with Section 12AB can Page 9 of 11 be taken

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)

आयकर अपीलीय अधिकरण न्याय पीठ मुंबई में। IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH

J.B Petit High School for Girls, Mumbai vs. CIT(Exemption), Mumbai

In the result, the Assessee’s appeal is allowed

ITA 4667/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2022-23

For Appellant: Shri Sukhsagar Sayal, Ld. ARFor Respondent: Shri Vivek Perampura, (CIT DR
Section 143Section 263

receipts are as per the object of the trust i.e. to provide education. Further, the Assessee has also submitted item wise breakup of application of income of Rs.7,73,39,821/-. The Assessee further submitted before the Ld. PCIT that, since the case of the Assessee was selected for ‘limited ... material available on the record, it is seen that the assessee has also claimed sum of accumulation as application of income towards the object of Trust during the year. Here, it is pertinent to mention that the assessee Trust has accumulated large sum for the year (Schedule-I/ITR

ACIT Central Circle-1(4), Mumbai vs. Anandilal & Ganesh Podar Society, Mumbai

In the result, the appeal filed by the Revenue stands dismissed

ITA 4000/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Jan 2026AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 11Section 12ASection 143(3)

actual expenditure or utilization of income for the objects of the trust. Accordingly, the said amount was disallowed from the expenditure claimed as application of income under section 11. 4. Before the learned CIT(A), the assessee submitted that the provisions had been made in accordance with consistent accounting practices ... that the solitary issue raised by the Revenue in the present appeal, namely, the allowability of provision for gratuity and leave encashment as application of income in the hands of a charitable trust registered under section 12A and claiming exemption under section 11, is no longer res integra. The learned

ACIT., Circle-5(1), Hyderabad vs. Penna Cement Industries Limited, Hyderabad

ITA 1084/HYD/2024[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19
For Appellant: Shri Sourabh Soparkar, Advocate Represented by Department : Dr. Narendra Kumar NFor Respondent: Dr. Narendra Kumar Naik, CIT-DR Date of Conclusion of Hearing : 11/11/2025
Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

exclusively for the purposes of carrying on business or profession. It was submitted by him that as the CSR expenditure (being an application of income) is not incurred for the purposes of carrying on business, such expenditure cannot be allowed as a deduction under the provisions of Section ... intention of the legislature as could be gathered from the “memorandum” to the Finance Act, 2014, the CSR expenditure, being an application of income, could not be allowed as a deduction for computing the taxable income of the assessee company. Elaborating further on his contention, the Ld. CIT-DR submitted

ACIT., Circle-5(1), Hyderabad vs. Penna Cement Industries Limited, Hyderabad

ITA 1083/HYD/2024[2017-18]Status: DisposedITAT Hyderabad21 Jan 2026AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आयकर अपीलसं./I.T.A. No.1083/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2017-18) Assistant Commissioner Of Income Tax, Circle-5(1), Hyderabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) Industries आयकर अपीलसं./I.T.A. No.1084/Hyd/2024 (निर्धारणवर्ष/ Assessment Year:2018-19) Assistant Commissioner Of Income Tax, Circle-5(1), Hydeabad. (अपीलार्थी/ Appellant) Vs. Penna Cement Industries Limited, Hyderabad. Pan: Aabcp2290D (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By : Shri Sourabh Soparkar, Advocate राजस्वकाप्रतिनिधित्व/ Department Represented By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing : 11/11/2025 घोषणा की तारीख/ Date Of Pronouncement : 21/01/2026 2

Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

exclusively for the purposes of carrying on business or profession. It was submitted by him that as the CSR expenditure (being an application of income) is not incurred for the purposes of carrying on business, such expenditure cannot be allowed as a deduction under the provisions of Section ... intention of the legislature as could be gathered from the “memorandum” to the Finance Act, 2014, the CSR expenditure, being an application of income, could not be allowed as a deduction for computing the taxable income of the assessee company. Elaborating further on his contention, the Ld. CIT- DR submitted

O P Jindal Foundation, Mumbai vs. Income Tax Officer Exem. Ward 2(2), Mumbai

In the result, both the appeals are allowed

ITA 6375/MUM/2025[2019-20]Status: DisposedITAT Mumbai21 Jan 2026AY 2019-20

Bench: Shri Pawan Singh

Section 11Section 143(1)Section 254(1)

audit report in Form 10B was filed on 31.10.2019. The Central Processing Centre (CPC) while processing the return of income not allowed the application of income under section 11/12 of the Income Tax Act as Form 10B was filed after filing return of income. The ld. CIT(A) confirmed

O P Jindal Foundation, Mumbai vs. Income Tax Officer Exem. Ward 2(2), Mumbai

In the result, both the appeals are allowed

ITA 6374/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Jan 2026AY 2018-19

Bench: Shri Pawan Singh

Section 11Section 143(1)Section 254(1)

audit report in Form 10B was filed on 31.10.2019. The Central Processing Centre (CPC) while processing the return of income not allowed the application of income under section 11/12 of the Income Tax Act as Form 10B was filed after filing return of income. The ld. CIT(A) confirmed

Colour Creation Pvt Ltd, Delhi vs. ACIT, Circle-4(2), Delhi

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

ITA 2418/DEL/2025[2017-18]Status: DisposedITAT Delhi21 Jan 2026AY 2017-18

Bench: Shrisatbeer Singh Godara & Shri Shris.Rifaur Rahmancolour Creation Pvt. Ltd., Vs. Assistant Commissioner Of Income Tax A-49, Naraina Industrial Area, Circle 4(2), Central Revenue Building, Phase-1, New Delhi-110028. I P Estate, New Delhi-110002. (Pan No. Aaecc0920A) (Appellant) (Respondent) Assessee By : None Revenue By : Shri Ajay Arora, Sr. Dr Date Of Hearing : 10.11.2025 Date Of Order : 21.01.2026 Order Per S. Rifaur Rahman: The Assesse Has Filed Appeal Against The Order Of The Ld. Addl/Jcit-7, Mumbai Dated 13.02.2025 For Assessment Year 2017-18, Wherein The Assesse Has Raised Following Grounds:- “1. On The Facts & Circumstances Of The Case, The Order Passed By The Learned Cit (Appeals) Nfac Is Bad, Both In The Eye Of Law & On The Facts. 2. On The Facts & Circumstances Of The Case, Learned Cit (Appeals) Nfac Has Erred Both On Facts & In Law In Passing The Order Without Giving Assessee A Proper & Adequate Opportunity Of Being Heard In Clear Violation Of Principle Of Natural Justice. 3.(I). On The Facts & Circumstances Of The Case, The Learned Cit (Appeals) Nfac Has Erred, Both On Facts & In Law, In Confirming The Assessment Order, Assessing The Loss Of The Assesseers. 11,10,00,840/- As Against The Returned Loss Of Rs. 11,13,22,840/-.

For Appellant: NoneFor Respondent: Shri Ajay Arora, Sr. DR
Section 143(2)Section 56(2)(viib)

share premium received during the year (verify applicability of section 56(2)(viib) or any other relevant section, reduction in profit because of application of income computation & disclosure standers , opening written down value of fixed assets as per ITR of current year is greater than closing written down value

DCIT Circle-1(1) (E), New Delhi vs. Guru Gobind Singh Educational Charitable Trust, New Delhi

In the result, appeal of the Revenue in ITA No

ITA 8504/DEL/2019[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Subodh Gupta, AdvFor Respondent: Shri Amit Jain, CIT- DR
Section 115BSection 12ASection 133(6)Section 68

establish the connection between Ms. Alka Gupta and Neo Bus Technology, the amount of Rs. 24,46,875/- was not allowed as application of income. The appellant has submitted that Ms. Alka Gupta is the proprietor of Neo Bus Technology and tax was deducted at source under

ACIT(Exemption), Circle-2, Ahmedabad vs. Shree Ramkrishna Seva Mandal Anand, Anand

In the result, appeal filed by the Revenue is dismissed

ITA 2237/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2023-24
For Appellant: Shri Mehul Thakker, A.RFor Respondent: Shri Rignesh Das, CIT.DR
Section 12ASection 250

Shree Ramkrishna Seva Mandal Anand] A.Y. 2023-24 - 8 – In the documentary evidences filed by the appellant to substantiate its claim of application of income, instead he has proceeded to disallow 10% of total expenses on adhoc basis without specifying any particular reason for the same. It is felt that ... appellant before the AO during the course of assessment proceedings, the initial onus which was casted upon it to substantiate its claim of application of income was duly discharged and the onus, then, shifted to the AO to point out any specific defect in the claim of expenditure made

Deputy Commissioner of Income Tax (Exemptions), Chennai vs. The Icici Foundation for Inclusive Growth, Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 2386/CHNY/2025[2012-13]Status: DisposedITAT Chennai20 Jan 2026AY 2012-13

Bench: Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Shri S.R. Raghunathashri S.R. Raghunathashri S.R. Raghunathashri S.R. Raghunathaआयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं././././Ita No.2 अपील

For Appellant: Mr. S.Sriram, AdvocateFor Respondent: Ms. E.Pavuna Sundari, CIT
Section 11(1)(d)Section 12ASection 80G

entire administrative expenditure of Rs.12,81,95,061/- was incurred wholly and exclusively for the objects of the trust and was claimed as application of income. Detailed bifurcation of expenses was furnished. It was specifically contended that no foreign travel expenditure was debited as alleged by the Assessing Officer.It

Incometax Officer Exemptions Ward, Tirunelveli vs. The Christian Businessmen Educational Fellowship, Kovilpatti

In the result, the appeal filed by the Revenue is dismissed

ITA 2395/CHNY/2025[2019-20]Status: DisposedITAT Chennai19 Jan 2026AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./ Ita No.2395/Chny/2025 "नधा"रण वष" /Assessment Year: 2019-20 The Income Tax Officer, The Christian Businessmen Exemptions Ward Vs. Educational Fellowship, Nellai City Centre, Rahmath Nagar, No.46, Alwar Street, Tiruchendur Road, Kovilpatti, Tirunelvali, Tamil Nadu-628501 Tamil Nadu-627011 [Pan: Aacat2359N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr.C.Sivakumar, Addl.Cit ""यथ" क" ओर से /Respondent By : Mr.R. Viswanthan, Ca सुनवाई क" तार"ख/Date Of Hearing : 07.01.2026 घोषणा क" तार"ख /Date Of Pronouncement : 19.01.2026

For Appellant: Mr.C.Sivakumar, Addl.CITFor Respondent: Mr.R. Viswanthan, CA
Section 11Section 12ASection 143(1)Section 143(1)(a)Section 154Section 80G

order of the Ld. CIT(A). It was submitted that the assessee is a registered charitable institution under section 12A and the application of income under section 11 cannot be examined or disallowed at :- 4 -: the stage of section 143(1). Any alleged inconsistency required verification and examination, which ... Once such registration is in force, the income of the trust is eligible for exemption under section 11, subject to verification of application of income, which necessarily requires examination of facts. The scope of adjustment under section 143(1) is limited to prima facie and apparent errors

Independent and Public Spirited Media Foundation, Bengaluru vs. Principal Commissioner of Income-Tax, (Central), Bengaluru

In the result appeal of the assessee is dismissed

ITA 625/BANG/2023[Nill]Status: DisposedITAT Bangalore16 Jan 2026

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : Na

For Appellant: S/Shri. A. Sheshadri, CA and Bhardwaj Sheshadri, AdvocateFor Respondent: Shri
Section 11Section 12Section 12ASection 133A

explanation to section 12AB. 14. The Pr. CIT (Central) erred in reaching findings considering whether or not sums expended by the Appellant constituted application of income within the meaning of section 11. 15. The cancellation of registration is bad in law, inter alia, as it is a disproportionate action even ... does not contain the nature of services to be rendered and thus, the Page 8 of 102 payments do not qualify to be 'application of income' towards the objectives of the trust v. assessee trust had focused on coverage of certain select/target issues by paying to entities to cover such