2025 (10) TMI 255 - AT - Income Tax

Registration under section 12AB denied as trust's activities are not 'charity' under section 2(15); appeals dismissed

ITAT upheld denial of registration under section 12AB, dismissing the assessee-trust's appeals. The tribunal agreed with the CIT(E) that no amount had ... Denial of registration u/s 12AB - no amount has been spent towards “Charity” as envisaged u/s 2(15) - HELD THAT:- The objectives of the assessee-trust has been claimed as to pursue “relief of the poor” and “education”, the activities being carried out by the assessee-trust failed to satisfy the conditions laid down in the case of Sole Trustee, LokaShikshana Trust [1975 (8) TMI 1 - SUPREME COURT] and New Noble Educational Society [2022 (10) TMI 855 - SUPREME COURT]. Accordingly, we find that the ld. CIT(E) was right in rejecting the application of the assessee-trust denying the registration of the assessee-trust under Section 12AB of the Act. Appeals of the assessee are dismissed. Appeals by the same assessee challenge orders of the Commissioner of Income Tax (Exemptions), Chennai, both dated 30/12/2024; matters were clubbed for hearing on common facts and grounds. The Tribunal proceeded on the lead appeal ITA No. 376/Chny/2025. The assessee has raised grounds attacking the CIT(E)'s order dated 30/04/2024 (record reference ITBA/EXM/F/EX...), asserting errors in the impugned exemption-related determination. The proceedings record recital of parties and representation. The Tribunal notes commonality of issues and hears the appeals together, addressing jurisdictional and merits aspects of the exemption order in a consolidated adjudication. Procedural consolidation and identification of a lead case frame the appeal for focused consideration of the exemptional relief claimed and the statutory/administrative basis of the CIT(E)'s findings.