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Charitable TrustsSection 12AASection 12AA30 judgments

HYDERABAD SCIENCE SOCIETY,HYDERABAD vs. DCIT., EXEMPTION CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1128/HYD/2024[2015-16]Status: DisposedITAT Hyderabad11 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1128/Hyd/2024 Assessment Year 2015-2016 Hyderabad Science Society, Hyderabad. The Dcit, Vs. Pin - 500 028. Exemption Circle-1(1), Telangana. Hyderabad. Pan Aaath3789F (Appellant) (Respondent) For Assessee : Sri P Murali Mohan Rao, Ca For Revenue : Dr. Narendra Kumar Naik, Cit-Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 11.03.2026 आदेश/Order

For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 12ASection 143Section 143(3)

consideration to rival contentions against and in support of the correctness of the CIT(E)'s order under challenge cancelling the assessee's Section 12AA registration. We find no reason to express our agreement with the Revenue's arguments supporting the same. This is for the precise reason that

UTTAR PRADESH MITRA MANDAL TRUST,DELHI vs. CIT (EXEMPTION), DELHI

Appeal is allowed for statistical purposes

ITA 964/DEL/2025[-]Status: DisposedITAT Delhi28 Jan 2026

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwaluttar Pradesh Mitra Mandal Trust, Vs Cit(Exemption), B-5/263, Sector-7, Rohini, Civic Centre, Delhi-110085 New Delhi (Appellant) (Respondent) Pan No. Aabtu1461C Assessee By : Sh. V. K. Sabharwal, Adv. & Sh. Ashok Babbar, Adv. Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 28.01.2026 Date Of Pronouncement: 28.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal Arises Against The Cit(Exemption), Delhi’S Din & Order No. Itba/Exm/F/Exm45/2024– 25/1071425041(1) Dated 20.12.2024, In Proceedings U/S 12Ab(1)(B)(Ii) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. V. K. Sabharwal, Adv. &For Respondent: Ms. Amish S. Gupt, CIT-DR
Section 12A

both the parties at length. Case file perused. 3. It emerges during the course of hearing that the learned CIT(Exemption) has refused section 12AA registration to the assessee after observing in para 5 of the impugned order that it had failed to file all the requisite information sought

NIH SAHAY UTTHANSAMITI,MADHUBANI vs. INCOME-TAX OFFICER (EXEMPTION), MUZAFFARPUR

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

ITA 96/PAT/2025[2015-16]Status: DisposedITAT Patna09 Jan 2026AY 2015-16
Section 11Section 12ASection 250

return declaring nil income. The Assessing Officer denied exemption under Section 11 of the Income Tax Act, 1961, because the assessee lacked Section 12AA registration. The CIT(A) upheld this decision.", "held": "The Tribunal noted that the assessee did not appear for hearings, but the order was passed without giving

SHRI GOSHALA,GURGAON vs. CIT EXEMPTION, CHANDIGARH

ITA 4263/DEL/2025[-]Status: DisposedITAT Delhi25 Nov 2025

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 12A

perused. 2. It emerges during the course of hearing that the assessee is aggrieved against the learned CIT(E)’s action rejecting its section 12AA registration application dated 13.11.2024 vide the following detailed discussion: - “2. In order to examine and verify whether the activities of the applicant society ... assessee’s and the Revenue’s vehement submissions. Learned CIT(DR), more particularly, strongly submits that the assessee has been rightly declined section 12AA registration as it had failed to explain the cash deposits made in its bank account maintained with Bank of Baroda. The Revenue could hardly dispute that

SHRI GOSHALA,GURGAON vs. CIT(EXEMPTIONS), CHANDIGARH

ITA 4262/DEL/2025[-]Status: DisposedITAT Delhi25 Nov 2025

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 12A

perused. 2. It emerges during the course of hearing that the assessee is aggrieved against the learned CIT(E)’s action rejecting its section 12AA registration application dated 13.11.2024 vide the following detailed discussion: - “2. In order to examine and verify whether the activities of the applicant society ... assessee’s and the Revenue’s vehement submissions. Learned CIT(DR), more particularly, strongly submits that the assessee has been rightly declined section 12AA registration as it had failed to explain the cash deposits made in its bank account maintained with Bank of Baroda. The Revenue could hardly dispute that

SHREE JAGAT GURU BRAHMANAND GAUSHALA SAMITI,PANIPAT vs. CIT(E), CHANDIGARH

ITA 297/DEL/2022[-]Status: DisposedITAT Delhi03 Nov 2025

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

Section 11Section 11(1)(d)Section 12A

Heard both the parties. Case file perused. 2. It emerges during the course of hearing that the learned CIT(Exemption) has refused section 12AA registration to the assessee vide his following detailed discussion: “6. After considering the submissions on record, it is observed that the applicant has shown an amount ... could be examined only in section 11 exemption proceedings since all what the learned CIT(Exemption) could consider at the time of section 12AA registration is the assessee’s object clauses vis-à-vis the corresponding proposed activities as per CIT(E) Vs. International Health Care Education & Research Institute

CYBOARD FOUNDATION, GURGAON,GURGAON, HARYANA vs. CIT EXEMPTIONS, CHANDIGARH, CHANDIGARH

ITA 2806/DEL/2025[2023-24]Status: DisposedITAT Delhi04 Aug 2025AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 12ASection 80G

parties. 3. It next emerges from a combined perusal of these case files that the CIT(Exemptions) has firstly rejected the assessee’s Section 12AA registration quoting its failure to file all of its supportive evidence despite affording various opportunities of hearing subject matter of adjudication in ITA No. 2806/Del/2025

CYBOARD FOUNDATION, GURGAON,GURGAON vs. CIT EXEMPTIONS, CHANDIGARH, CHANDIGARH

ITA 2679/DEL/2025[2023-2024]Status: DisposedITAT Delhi04 Aug 2025AY 2023-2024

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 12ASection 80G

parties. 3. It next emerges from a combined perusal of these case files that the CIT(Exemptions) has firstly rejected the assessee’s Section 12AA registration quoting its failure to file all of its supportive evidence despite affording various opportunities of hearing subject matter of adjudication in ITA No. 2806/Del/2025

BAB-E-REHMAT EDUCATIONAL SOCIETY,MUMBRA THANE vs. AO EXEMTION WARD THANE, QUERESHI MANSION

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

ITA 3119/MUM/2025[2023-24]Status: DisposedITAT Mumbai24 Jun 2025AY 2023-24

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm Bab-E-Rehmat Educational Society Ao Exemption Ward Thane Fakir Shah Baba Hill Road, Near Darul Falah, Near Sahil Hotel, Kausa, Vs. Mumbai – 400612. Pan/Gir No. Aabtb7190H (Appellant) : (Respondent) Assessee By : Shri Himanshu Gandhi Respondent By : Shri Leyaqat Ali Aafaqui, Sr. Ar. Date Of Hearing : 23.06.2025 Date Of Pronouncement : 24.06.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Addl/Jcit (A)-2, Bengaluru (‘Ld. Cit(A)’ For Short), Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2023-24. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1) Rejection Of Approval Claimed U/S 12Aa Is Bad In Law Assessee Having Exemption Certificate U/S 12Aa Dated 25 April 2016, As Per Old Registration Process Once An Organization Obtains Section 12Aa Registration, The Validity Of The Registration Is Perpetual Unless It Is Cancelled Or Revoked By The Income Tax Department. Unlike Certain Registrations Requiring Periodic Renewal, Section 12Aa Of Income Tax Act Has No Expiration Date Or A Specific Time Limit. Which Is Valid For Life Time Of Society/Trust That Means Appellant Is Eligible For 12Aa Registration Till Cancellation Or Revoked By The Income Tax Department. Bad-E-Rehmat Educational Society

For Appellant: Shri Himanshu GandhiFor Respondent: Shri Leyaqat Ali Aafaqui, SR. AR
Section 11Section 12ASection 143Section 250

Assessee having Exemption certificate U/S 12AA dated 25 April 2016, as per Old Registration Process Once an organization obtains Section 12AA registration, the validity of the Registration is perpetual unless it is cancelled or revoked by the Income Tax Department. Unlike certain registrations requiring periodic renewal, Section 12AA of Income

DHARMBHASKAR RASHTRASANT SHRIPACHLEGAVKAR MAHARJ PRATISHTAN,PUNE vs. EXEMPTION WARD 1(2), PUNE, PUNE

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

ITA 2799/PUN/2024[2012-13]Status: DisposedITAT Pune18 Jun 2025AY 2012-13
For Appellant: \nShri Abhay Shastri & Jasraj SutarFor Respondent: \nShri Akhilesh Srivastava
Section 11Section 11(1)(d)Section 12Section 12ASection 143(3)Section 147Section 2(24)

n1860, and BPT Act, 1950 (No. F-27645, Pune, 14/02/2011), received\nRs.34,92,076 in donations for charitable purposes (Building Fund). It\nobtained Section 12AA registration on 02/12/2016 during appeal\npendency (06/08/2016), meeting the proviso's conditions.\nΟ\nThe Assessing Officer's disregard of ITAT's remand directive to\nconsider

DHARMBHASKAR RASHTRASANT SHRIPACHLEGAVKAR MAHARJ PRATISHTAN,PUNE vs. EXEMPTION WARD 1(2), PUNE, PUNE

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

ITA 2736/PUN/2024[2011-12]Status: DisposedITAT Pune18 Jun 2025AY 2011-12
For Appellant: \nShri Abhay Shastri & Jasraj SutarFor Respondent: \nShri Akhilesh Srivastava
Section 11Section 11(1)(d)Section 12Section 12ASection 143(3)Section 147Section 2(24)

n1860, and BPT Act, 1950 (No. F-27645, Pune, 14/02/2011), received\nRs.34,92,076 in donations for charitable purposes (Building Fund). It\nobtained Section 12AA registration on 02/12/2016 during appeal\npendency (06/08/2016), meeting the proviso's conditions.\nΟ The Assessing Officer's disregard of ITAT's remand directive to\nconsider

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(3), CHENNAI

ITA 3297/CHNY/2024[2020-21]Status: DisposedITAT Chennai06 Jun 2025AY 2020-21
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

npenalty levied u/s.270A of the Act\n4. Brief facts are that the assessee is a public charitable trust formed\non 02.04.2012 and enjoyed section 12AA registration w.e.f. 29.05.2012\nvide registration dated 26.12.2012. The assessee is noted to be running\nan Engineering College and has claimed exemption u/s.11

ST. JOSHEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

ITA 3296/CHNY/2024[2019-20]Status: DisposedITAT Chennai06 Jun 2025AY 2019-20
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

npenalty levied u/s.270A of the Act\n4. Brief facts are that the assessee is a public charitable trust formed\non 02.04.2012 and enjoyed section 12AA registration w.e.f. 29.05.2012\nvide registration dated 26.12.2012. The assessee is noted to be running\nan Engineering College and has claimed exemption u/s.11

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

In the result, all the appeals filed by the assessees are allowed

ITA 3295/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

penalty levied u/s.270A of the Act 4. Brief facts are that the assessee is a public charitable trust formed on 02.04.2012 and enjoyed section 12AA registration w.e.f. 29.05.2012 vide registration dated 26.12.2012. The assessee is noted to be running an Engineering College and has claimed exemption u/s.11

ST. JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

ITA 3294/CHNY/2024[2020-21]Status: DisposedITAT Chennai06 Jun 2025AY 2020-21
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

npenalty levied u/s.270A of the Act\n4. Brief facts are that the assessee is a public charitable trust formed\non 02.04.2012 and enjoyed section 12AA registration w.e.f. 29.05.2012\nvide registration dated 26.12.2012. The assessee is noted to be running\nan Engineering College and has claimed exemption u/s.11

ST.JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

In the result, all the appeals filed by the assessees are allowed

ITA 3293/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

penalty levied u/s.270A of the Act 4. Brief facts are that the assessee is a public charitable trust formed on 02.04.2012 and enjoyed section 12AA registration w.e.f. 29.05.2012 vide registration dated 26.12.2012. The assessee is noted to be running an Engineering College and has claimed exemption u/s.11

LORD KRISHNA UCHYA SHIKSHA PRASAR SAMITI, DATIA,DATIA vs. ACIT,DATIA, DATIA

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

ITA 128/AGR/2022[2015-16]Status: DisposedITAT Agra29 May 2025AY 2015-16
Section 10Section 10(23)(C)Section 11Section 12ASection 142Section 147Section 148Section 250

have rejected the assessee's section 11 exemption\nclaimed for the A.Y. 2017-18 in the precise reason that the\nId.CIT(Exemption) granted Section 12AA registration on 30.09.2020\nwhich could not be extended as carrying retrospective effect.\n4. The Revenue vehemently quote hon'ble jurisdictional high court's\ndecision ... where the appeal was allowed. The Tribunal referred to a co-ordinate bench's decision, which held that the Section 12AA registration, obtained before the framing of assessment, should not be denied retrospective benefit. The Tribunal accepted the assessee's grievance.", "result": "Allowed", "sections

LORD KRISHN A UCHYA SHIKSHA PRASAR SAMITI,DATIA vs. ACIT, DATIA, DATIA

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

ITA 122/AGR/2022[2016-17]Status: DisposedITAT Agra29 May 2025AY 2016-17

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwal[Through Video Conferencing]

Section 10Section 10(23)(C)Section 11Section 12ASection 142Section 147Section 148Section 250

rejected the assessee’s section 11 exemption claimed for the A.Y. 2017-18 herein for the precise reason that the ld.CIT(Exemption) granted Section 12AA registration on 30.09.2020 which could not be extended as carrying retrospective effect. 4. The Revenue vehemently quote hon’ble jurisdictional high court’s decision ... come on record that at the time of framing assessment herein dated 10.09.2021, the assessee had very well succeeded in getting Section 12AA registration. We thus quote section 12A 2nd proviso to hold that ITA Nos.122 & 128/Agr/2022 benefit of such a registration could not be denied as the re- assessment

SOCIAL EDUCATIONAL AND WELFARE ASSOCIATION,HALDWANI vs. ITO, HALDWANI, HALDWANI

Appeal is partly allowed for statistical purposes

ITA 184/DDN/2024[2021-22]Status: DisposedITAT Dehradun21 Mar 2025AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Taran Deep Singh, AdvFor Respondent: Sh. Amar Pal Singh, Sr. DR
Section 11Section 12ASection 154Section 68

course of hearing that both the lower authorities ought to have treated the assessee is entitled for section 11 exmeption once it carries section 12AA registration since 12.07.2010. The Revenue on the other hands seeks to buttress the point that given the fact that once the assessee could not plead ... situation, Mr. Singh firstly invited our attention to the assessee’s paper book pages 7 to 9 indicating it to have been granted section 12AA registration on 05.04.2022. He further takes us to the statutory amendment in section 12AB; inserted by the taxation and other laws relaxation and amendment

LORD KRISHNA UCHYA SHIKSHA PRASAR SAMITI, DATIA,DATIA vs. ITO, DATIA, DATIA

Appeal is allowed

ITA 129/AGR/2022[2017-18]Status: DisposedITAT Agra10 Feb 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwallord Krishna Uchya Vs. Cit(A)/Nfac, Shiksha Prasar Samiti, Delhi House Of Ram Kishoare Rawat, Holipura, Datia, M.P.-475661 "ायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaal3677K Appellant .. Respondent

For Appellant: Sh. Ashok Vijayawargiya, CAFor Respondent: Sh. Shalendra Shrivastava, Sr. DR
Section 11Section 12ASection 147

assessee’s section 11 exemption claimed for the A.Y. 2017-18 herein for the precise reason that the ld. CIT(Exemption) granted Section 12AA registration on 30.09.2020 which could not be extended as carrying retrospective effect. 4. The Revenue vehemently quote hon’ble jurisdictional high court’s decision ... come on record that at the time of framing assessment herein dated 10.09.2021, the assessee had very well succeeded in getting Section 12AA registration. We thus quote section 12A 2nd proviso to hold that benefit of such a registration could not be denied as the re-assessment had been granted

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