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ITAT Chennai Restores 12AB & 80G Applications – Convention Centre Not Inherently Commercial

Case Law Details

TaxGuru Citation
2025 taxguru.in 8872
Case Name
Maditssia Trade & Convention Centre Vs CIT (Exemptions) (ITAT Chennai)
Date of Judgement/Order
Only available for paid members
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Maditssia Trade & Convention Centre Vs CIT (Exemptions) (ITAT Chennai)

ITAT Chennai remits back applications for 12AB registration and 80G approval of Maditssia Trade Centre. Tribunal holds that proposed convention centre cannot be treated as per se commercial; directs CIT(E) to reconsider after giving assessee opportunity.

ITAT Chennai Restores 12AB & 80G Applications of Maditssia Trade Centre- Convention Centre Not Per Se Commercial – One More Opportunity Allowed- Natural Justice Applied: Tribunal Remits Trust’s Case Back to CIT(E)- Registration & 80G Approval Reconsideration Ordered by ITAT

ITAT Chennai Restores 12AB Registration & 80G Approval Applications – Maditssia Trade & Convention Centre

In Maditssia Trade & Convention Centre Vs CIT(E), Chennai (ITA Nos.1919 & 1920/Chny/2025, order dated 29.09.2025), Chennai ITAT dealt with rejection of applications for registration u/s 12AB & approval u/s 80G.

The Assessee had filed Form 10AB on 21.11.2024 seeking registration u/s 12AB. CIT(E) rejected the application on 27.06.2025, holding that the proposed activities of running a convention centre appeared predominantly commercial in nature. It was observed that no evidence was furnished regarding charitable use, free or subsidised access, or advancement of public purpose. Consequently, approval u/s 80G(5) was also rejected.

Before Tribunal, the Assessee submitted that evidence of charitable activities existed but could not be filed before CIT(E). It pleaded for one more opportunity to demonstrate that the convention centre was structured to serve charitable purposes.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,879

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