AO Lacks Authority to Deny Section 11 Exemption After Granting Section 12AA Registration

DCIT (Exemptions)-1(1) Vs Indian Institute for Human Settlements (ITAT Mumbai) Summary: The assessee, a non-profit corporation registered under Section 25 of the Companies Act, 1956, and recognized as a charitable organization under Section 12A, faced scrutiny for AY 2013-14 after declaring NIL income. The AO denied exemption under Section 11, claiming the institution’s consultancy and seminar fee income was commercial and non-educational. The assessee argued its activities were educational and incidental to its objectives, supported by valid Section 12AA registration. The Tribunal ruled the...