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“registration under section 12A”

Charitable TrustsSection 12ASection 12A2,527 judgments

The decision most relied on for registration under section 12A is ACIT v. Surat City Gymkhana (300 ITR 214), cited in 125 judgments on BharatTax.

Leading authorities on registration under section 12A

ACIT v. Surat City Gymkhana
300 ITR 214 · 2008 · Supreme Court
125
citing judgments

Once an institution receives registration under Section 12AA, the Assessing Officer must compute its income as per Section 11, focusing only on the application of income and not re-examining the charitable nature of its activities. The Supreme Court also clarified the meaning and scope of 'general public utility' under Section 2(15).

Ananda Social and Educational Trust v. CIT
426 ITR 340 · 2020 · Supreme Court
116
citing judgments

For registration under Section 12AA, the Commissioner (Exemptions) must examine the objects of the trust and the genuineness of its proposed activities, even if the trust has not yet commenced actual charitable activities or incurred expenditure.

Ahmedabad Urban Development Authority v. ACIT
396 ITR 323 · 2017 · High Court
108
citing judgments

Development authorities can continue to be regarded as existing for a 'Charitable Purpose' under Section 2(15) of the Income Tax Act, even after the introduction of the proviso to that section. The contention that such authorities automatically lose their charitable status due to the proviso is incorrect.

CIT v. Gujarat Maritime Board
295 ITR 561 · 2007 · Supreme Court
98
citing judgments

A statutory corporation undertaking activities that generate income qualifies as a charitable entity under Section 2(15) if its dominant object is general public utility and it is legally obligated to apply its income solely for that purpose, even if the activities appear to be in the nature of trade or business. Such an entity is entitled to registration under Section 12A and exemptions under Section 11.

CIT v. Dawoodi Bohra Jamat
364 ITR 31 · 2014 · Supreme Court
83
citing judgments

A trust's objects, even if based on religious tenets, can qualify as charitable for tax exemptions if its benefits are not exclusively restricted to a particular religious community or caste.

CIT v. Ahmedabad Rana Caste Association
140 ITR 1 · 1983 · Supreme Court
82
citing judgments

An object beneficial to a section of the public, as distinguished from an individual or group of individuals, qualifies as an object of general public utility under Section 2(15) and hence a charitable purpose. This applies even if the benefits are restricted to a specific caste, community, or professional group.

CIT v. Parma Nand
268 ITR 172 · 2004 · High Court
81
citing judgments

Whether there was sufficient cause for delay in making applications for registration under section 12A and 80G is always a question of fact, and contumacious conduct by the assessee must be established for levying penalty under section 271C for non-deduction of TDS.

Barendra Prasad Ray v. ITO
129 ITR 295 · 1981 · Supreme Court
80
citing judgments

When determining if an activity serves charitable purposes for tax exemption, the primary consideration is whether its predominant object is to make a profit or to carry out charitable activities.

Judgments citing registration under section 12A

Global Health Research and Management Institute, Udaipur vs. Pr. CIT(Central), Jaipur

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

ITA 397/JODH/2019[2019-20]Status: DisposedITAT Jodhpur25 Jan 2023AY 2019-20

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

Section 115BSection 12ASection 13Section 13(1)(c)Section 153A

power of transfer of cases has been given from one Assessing Officer to other Assessing Officer and not from CIT to CIT. Therefore, registration under section 12A or approval under section 10(23C)(vi) can be withdrawn only by the prescribed authority who is empowered to grant the same. Notification ... thus observed that: 16. In the instant case, the petitioner is a registered society, which was earlier granted registration under Section 12A on 1-4-1999. A survey was conducted at the business premises on 20-9-2002, from where documents were impounded. The registration was cancelled for the assessment

Mahadevia Charitable Trust, Ahmedabad vs. Pr. CIT(Central), Jaipur

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

ITA 396/JODH/2019[2019-20]Status: DisposedITAT Jodhpur25 Jan 2023AY 2019-20

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 153A

power of transfer of cases has been given from one Assessing Officer to other Assessing Officer and not from CIT to CIT. Therefore, registration under section 12A or approval under section 10(23C)(vi) can be withdrawn only by the prescribed authority who is empowered to grant the same. Notification ... thus observed that: 16. In the instant case, the petitioner is a registered society, which was earlier granted registration under Section 12A on 1-4-1999. A survey was conducted at the business premises on 20-9-2002, from where documents were impounded. The registration was cancelled for the assessment

Suresh Raj Jaskanwar Jain Surana Foundation, New Delhi vs. CIT(E), New Delhi

The appeal is dismissed as withdrawn

ITA 7255/DEL/2019[2019-20]Status: DisposedITAT Delhi18 Jan 2023AY 2019-20

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2019-20

Section 12ASection 80G(5)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’, NEW DELHI BEFORE SH. N. K. BILLAIYA, ACCOUNTANT MEMBER AND SH

Shri Ram Education & Graminvikas Charitable Trust, Valsad vs. Income Tax Officer ( Exemption Ward), Surat

In the result, this appeal of the assessee is dismissed

ITA 213/SRT/2018[2013-14]Status: DisposedITAT Surat16 Jan 2023AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainishri Ram Education & I.T.O., (Exemption Ward) Graminvikas Charitable Trust, Aayakar Bhavan, Vs. Jauagauri Park, Hathikhana, Majura Gate, Dharampur, Surat. Valsad-396050. Pan No. Aalts 324 F Appellant/ Assessee Respondent/ Revenue

Section 10(23)(C)Section 11aSection 12ASection 133(6)Section 142(1)Section 254(1)

SC/165 Taxman 533(2008). The Hon’ble Apex Court clearly held that conjoint reading of section 11,12 & 12A makes it clear that registration under section 12A is a condition precedent for availing benefit under section 11&12. Similar view was taken by Chennai Tribunal in Veeraval Trust

Shri Khijda Trust, Junagadh vs. The Commissioner of Income Tax (Exemptions), Ahmedabad

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

ITA 54/RJT/2018[2016-17]Status: DisposedITAT Rajkot11 Jan 2023AY 2016-17

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12A

IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT (Conducted Through Virtual Court) Before: Shri Waseem Ahmed, Accountant Member And

Prajapati Samaj Maoli Bazar, Na vs. Arivs.Additional/Joint/Deputy/Assistant Commissioner of Income Tax/Income Tax Officer, National E-Assessment Centre, Delhi

In the result, the grounds of appeal raised by the assessee is allowed

ITA 308/SRT/2022[2018-19]Status: DisposedITAT Surat09 Jan 2023AY 2018-19

Bench: Shri Pawan Singh(Virtual Hearing) Prajapati Samaj Maroli Bazar, Additional/Joint/Deputy/Assistant C/O-Ganpatbhai Mistri, At Commissioner Of Income Vs. Mahuvar, Post- Maroli Bazar, Tax/Income Tax Officer, Taluka: Jalalpore, National E-Assessment Centre, Navsari-396436. (Gujarat) Delhi. Pan No. Aabtp 2604 E Appellant/ Assessee Respondent/ Revenue

Section 11Section 12ASection 12A(2)Section 254(1)

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH (SMC), SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER (Virtual hearing) Prajapati Samaj

Madresa Himayatul Islam Bachchon Ka Ghar, Bardoli vs. Income Tax Officer, Exemption Ward, Surat

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

ITA 279/SRT/2022[2017-18]Status: HeardITAT Surat02 Jan 2023AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Madresa Himayatul Islam Bachchon Ka I.T.O. Ghar, Exemption Ward, Vs. Ground Floor Bachchon Ka Ghar, Surat. Kadod, Bardoli-394335. Pan No. Aadtm 1802 F Appellant/ Assessee Respondent/ Revenue

Section 115BSection 12ASection 133(6)Section 144Section 249Section 249(4)Section 254(1)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH (SMC), SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER (Physical hearing) Madresa Himayatul

Shree Hari Ram Charitable Trust, Surat vs. ITO Exemption, Surat

In the result, the appeal of assessee is treated as dismissed being infructuous

ITA 248/SRT/2022[2016-17]Status: HeardITAT Surat02 Jan 2023AY 2016-17

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Shree Hari Ram Charitable Trust, I.T.O.(Exemptions), 304, Meghdhanush Complex, Ward-Surat. Vs. Adajan Patia, Adajan Surat, Gujarat, India- 395009. Pan No. Aajts 1057 L Appellant/ Assessee Respondent/ Revenue

Section 10Section 11Section 11(1)(A)Section 12ASection 154Section 254(1)

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND DR. ARJUN LAL SAINI

M/S. Srinivas Institute of Medical Science and Research Centre, Mangalroe vs. The Principal Commissioner of Income Tax (Central), Bengaluru

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

ITA 533/BANG/2022[N/A]Status: DisposedITAT Bangalore30 Dec 2022

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: N.A.

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Dr. G. Manoj Kumar, D.R
Section 10Section 11Section 12ASection 269S

educational institutions. The AO, thereafter, concluded that voluntary contributions are nothing but a capitation fee. It is seen that the assessee enjoys registration under section 12A of the Act and except for the compliant of the AO that the assessee received voluntary contribution, there has been no other charge

Shree Bhairav Seva Samiti, Mumbai vs. Income Tax Officer(Exexmption), Thane

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

ITA 2225/MUM/2022[2016-17]Status: DisposedITAT Mumbai08 Dec 2022AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Himanshu GandhiFor Respondent: Ms. Richa Gulati
Section 11Section 12(1)(b)Section 12ASection 139(4)Section 143(1)Section 154Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH

Zenith Charitable Trust, Mumbai vs. CIT (E), Mumbai

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

ITA 1153/MUM/2019[2018-19]Status: DisposedITAT Mumbai02 Dec 2022AY 2018-19

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Poojan MehtaFor Respondent: Shri Prabhat Kumar Gupta
Section 12ASection 36ASection 80G

trust has been registered with Charity Commissioner, Mumbai on 07/12/2013 vide registration No. E – 29998 (Mumbai). The assessee filed an application for registration under section 12A of the Act in the prescribed Form No. 10B. Accordingly, notice was sent to the assessee requiring it to furnish account details/documents like

Zenith Charitable Trust, Mumbai vs. CIT (E), Mumbai

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

ITA 1152/MUM/2019[2018-19]Status: DisposedITAT Mumbai02 Dec 2022AY 2018-19

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Poojan MehtaFor Respondent: Shri Prabhat Kumar Gupta
Section 12ASection 36ASection 80G

trust has been registered with Charity Commissioner, Mumbai on 07/12/2013 vide registration No. E – 29998 (Mumbai). The assessee filed an application for registration under section 12A of the Act in the prescribed Form No. 10B. Accordingly, notice was sent to the assessee requiring it to furnish account details/documents like

Lady Tata Memorial Trust, Mumbai-400001 vs. Commissioner of Income Tax (Exemptions), Mumbai-400026

ITA 1158/MUM/2022[2022-23]Status: DisposedITAT Mumbai30 Nov 2022AY 2022-23

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2022-23

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Smt Shailja Rai, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)Section 80G(5)(iv)

PCIT subject to certain conditions in the light of the provisions contained in the scheme of Income Tax Act, 1961 consequent upon the registration under section 12A, approval under section 80G of the Act sought for by the assessee cannot be subjected to any condition as there is an “inbuilt

Lady Meherbai D Tata Education Trust, Mumbai-400001 vs. Commissioner of Income Tax (Exemptions), Mumbai

ITA 1157/MUM/2022[2022-23]Status: DisposedITAT Mumbai30 Nov 2022AY 2022-23

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2022-23

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Smt Shailja Rai, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)Section 80G(5)(iv)

PCIT subject to certain conditions in the light of the provisions contained in the scheme of Income Tax Act, 1961 consequent upon the registration under section 12A, approval under section 80G of the Act sought for by the assessee cannot be subjected to any condition as there is an “inbuilt

Visvesvaraya Technological University, Belgaum vs. CIT, Bangalore

ITA 8/BANG/2016[N.A.]Status: DisposedITAT Bangalore25 Nov 2022

Bench: Shri.Chandra Poojari & Smt. Beena Pillaiassessment Year : N.A. Visvesvaraya Technological University, The Commissioner Of Jnana Ganga Campus, Vs. Income-Tax (Exemptions), Belagavi. Bengaluru. Pan : Aaajv 0064 F Appellant Respondent : Shri. M.V. Seshachala, Sr. Standing Assessee By Counsel & Shri Shiva Prasad Reddy, I.T.P Revenue By : Shri Dilip, Standing Counsel Date Of Hearing : 15.09.2022 Date Of Pronouncement : 25.11.2022 O R D E R Per Beena Pillaipresent Appeal Arises Out Of Order Dated 28/01/2021, Passed By Hon’Ble Karnataka High Court In Ita No.825/2018. Brief Facts Of The Case Are As Under: 2. In The First Round Of Appeal The Assessee Raised Following Grounds Before This Tribunal Against Order Passed By The Ld.Cit(E), Dated 08/12/2015: 1. The Impugned Order Passed By The Learned Commissioner Of Income- Tax (Exemptions), Bengaluru [Hereinafter Referred To As The Cit(E)] Under Section 12A Of Income-Tax Act, 1961 (Hereinafter Referred To As The I-T Act), To The Extent It Is Not Retrospective In Effect, Is Arbitrary, Erroneous, Unreasonable & Opposed To The Facts & Circumstances Of The Case & The Law.

For Respondent: Shri. M.V. Seshachala, Sr. Standing
Section 10(23)(C)Section 12ASection 12A(1)(a)Section 80G

Proviso to section 12A(1)(a)(i) of the I-T Act, inasmuch as the Appellant had filed its first application for registration under section 12A of the Act on 25,05.1999 and clause (i) of the Proviso to section 12A(1)(a) stood attracted to its case. The learned ... retrospective effect from 01.04.1998 and, as the earlier applications filed by the Appellant were not considered favourably only for want of such amendments, registration under section 12A ought to be granted from the date from which the amendments are effective, and not prospectively. 4. The learned CIT(E) has erred

Bhavnagri Halai Memon Jamat, Mumbai vs. Income Tax Officer (Exemption) 1(1), Mumbai

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

ITA 1676/MUM/2022[2012-13]Status: DisposedITAT Mumbai15 Nov 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Ito(Exemption)1(1) 6Th Floor, Cumballa Hill Bhavnagari Halai Memon Jamat Mtnl, Te Building, Peddar C/O Umer Hall Trust, Road, Dr. Gopalrao 11/13 Masjid Cross Lane, Vs. Mumbai- 400 003 Deshmukh Marg, Mumbai- 400 002 (Appellant) (Respondent) Pan No. Aaatb7848R Assessee By : Shri. Mudassir H. Deshmukh, Ca Revenue By : Shri. Chetan M. Kacha, Sr. Ar. Date Of Hearing: 14.11.2022 Date Of Pronouncement: 15.11.2022

For Appellant: Shri. Mudassir H. Deshmukh, CAFor Respondent: Shri. Chetan M. Kacha, Sr. AR
Section 11Section 12Section 12ASection 143(3)Section 147Section 148Section 234b

noted that, income of the assesses was assessed by denying exemption under section 11 and 12 due to non submission of certificate of registration under section 12A of the Act which could not be submitted at the time of assessment proceedings. The learned CIT submitted that even before him though ... Both the lower authorities have denied the exemption as assessee failed to produce the copy of the certificate of registration under section 12A of the Act. Now, before us a certificate confirming the registration of the trust under section 12A is made available. Assessee submits that same was also submitted

Sadras Venkatarama Chetty Charities, Chennai vs. ITO ( Exemptions ) Ward - 2, Chennai

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

ITA 544/CHNY/2022[2015-2016]Status: DisposedITAT Chennai19 Oct 2022AY 2015-2016

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 544/Chny/2022 िनधा"रण वष"/Assessment Year:2015-16 Sadras Venkatarama Chetty Charities, Vs. The Income Tax Officer No. 1, Audiappa Naicken Street, (Exemptions), Ward – 2, George Town, Chennai 600 001. Aayakar Bhavan, Chennai 600 034. [Pan:Aabas2781C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri J. Prabhakar, Ca ""थ" की ओर से/Respondent By : Shri K.N. Dhandapani, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.09.2022 घोषणा की तारीख /Date Of Pronouncement : 19.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) – National Faceless Appeal Centre [Nfac], New Delhi, Dated 18.05.2022 Relevant To The Assessment Year 2015-16. 2. Facts Are, In Brief, That The Assessee Sadras Venkatarama Chetty Charities Filed The Return Of Income On 05.11.2015 In Itr-7 Declaring An Income Of Nil After Claiming Deduction Under Section 11 Of The Income

For Appellant: Shri J. Prabhakar, CAFor Respondent: Shri K.N. Dhandapani, Addl. CIT
Section 11Section 12ASection 264

claiming deduction under section 11 of the Income 2 I.T.A. No.544/Chny/22 Tax Act, 1961. As the assessee has filed the ITR declaring the registration under section 12A “N” (No) under relevant column under “other details” in the return uploaded, the Assessing Officer, CPC disallowed the claim of exemption and determined

Maharashtra Housing & Area Development Authority, Mumbai vs. Asst CIT (E) 2(1), Mumbai

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

ITA 5597/MUM/2017[2013-14]Status: DisposedITAT Mumbai12 Oct 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.5597/Mum/2017 (निर्धारण वर्ा / Assessment Year: 2013-14) Maharashtra Housing & Acit (Exemption)-2(1) बिधम/ Area Development Piramal Chambers, Vs. Office Of Finance Lalbaug, Mumbai- Controller, Mhada, 4Th 400012. Floor, Griha Nirman Bhavan, Kala Nagar, Bandra (E), Mumbai- 400051. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaajm0344H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Nishant Thakkar/Ms. Jasmine Amalsadvala Revenue By: Shri S. H. Usmani (Dr) सुनवाई की तारीख / Date Of Hearing: 19/09/2022 घोषणा की तारीख /Date Of Pronouncement: 12/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-01, Mumbai Dated 28.06.2017 For Assessment Year 2013-14. 2. The Grounds Of Appeal Preferred By Assessee Are As Under: - “1.0 Denial Of Exemption Under S. 11 The Learned Cit(A) Erred On Facts & Circumstances Of The Case & In Law In Upholding The Assessment Order Appealed Against Denying Exemption Under S.11 Of The Act. Relief Claimed: The Appellant Be Granted Exemption Under S.11 Of The Act. 2.0 Engaged In Business:

For Appellant: Shri Nishant Thakkar/Ms. JasmineFor Respondent: Shri S. H. Usmani (DR)
Section 11(1)(a)Section 11(2)Section 234B

appeal are taken up together as both these grounds are interconnected. The assessee has been claiming the benefit of registration under section 12A of the Act. The Assessing Officer denied the exemption available to the assessee under section 11 of the Act on the ground that the activities

Sir Dorabji Tata Trust, Mumbai vs. CIT (Exemptions), Mumbai

ITA 2206/MUM/2021[AY 2022-2023 TO AY 2026-27]Status: DisposedITAT Mumbai29 Sept 2022

Bench: Shri Kuldip Singh & Shri Amarjit Singhassessment Years: 2022-23 To 2026-27 Sir Ratan Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats1013P Pedder Road, Mumbai – 400 026 (Appellant) (Respondent) Assessment Years: 2022-23 To 2026-27 Sir Dorabji Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats0494G Pedder Road, Mumbai – 400 026 (Appellant) (Respondent)

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Shri Kailash Kanojia, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)(iv)

PCIT subject to certain conditions in the light of the provisions contained in the scheme of Income Tax Act, 1961 consequent upon the registration under section 12A, approval under section 80G of the Act sought for by the assessee cannot be subjected to any condition as there is an “inbuilt

Sit Ratan Tata Trust, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

ITA 2204/MUM/2021[AY 2022-23 TO AY 2026-27]Status: DisposedITAT Mumbai29 Sept 2022

Bench: Shri Kuldip Singh & Shri Amarjit Singhassessment Years: 2022-23 To 2026-27 Sir Ratan Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats1013P Pedder Road, Mumbai – 400 026 (Appellant) (Respondent) Assessment Years: 2022-23 To 2026-27 Sir Dorabji Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats0494G Pedder Road, Mumbai – 400 026 (Appellant) (Respondent)

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Shri Kailash Kanojia, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)(iv)

PCIT subject to certain conditions in the light of the provisions contained in the scheme of Income Tax Act, 1961 consequent upon the registration under section 12A, approval under section 80G of the Act sought for by the assessee cannot be subjected to any condition as there is an “inbuilt