Indian Institute of Management Sirmaur Vs CIT(E) (ITAT Chandigarh)
Income Tax Appellate Tribunal (ITAT), Chandigarh Bench, has ruled in favor of the Indian Institute of Management (IIM) Sirmaur, overturning a decision by the Commissioner of Income Tax (Exemptions) (CIT(E)) that denied the institution registration under Section 10(23C)(iii) of the Income Tax Act. The dispute centered on a procedural misstep in the application process, rather than the educational activities of the esteemed institution.
The Indian Institute of Management Sirmaur, a Centrally Funded Institution of National Importance, was established by the Government of India in 2015. As a relatively new addition to the prestigious IIM family, it is mandated to deliver high-quality management education, foster research, and provide consultancy services. Initially registered as a Society in August 2015, IIM Sirmaur transitioned into an Institute through an Act of Parliament on December 31, 2017, and is now governed by the Indian Institutes of Management Act, 2017. Its financial accounts are subject to audit by the Comptroller and Auditor General (C&AG). The institution offers a range of programs, including undergraduate, postgraduate, doctoral, and executive education.
The core of the appeal arose from IIM Sirmaur’s application for tax exemption. The institution initially sought provisional registration in Form 10A on March 16, 2024, which was subsequently granted in Form 10AC on March 23, 2024, under sub-clause (A) of clause (iv) of the first proviso to clause (23C) of Section 10 of the Act. This specific sub-clause is applicable to entities applying for registration before commencing their activities. However, IIM Sirmaur had already begun its operations in 2015.
