Abhinay Taranga Trust Vs ITO (ITAT Bangalore)
Registration Granted After Return Filing but Before Processing: Can CPC Deny a Trust’s Section 11 Exemption?
A trust filed its return claiming exemption under section 11 while holding provisional registration. It obtained final registration only later. By the time the Centralised Processing Centre (CPC) processed the return, however, the final registration had been granted with effect from the very assessment year for which exemption was claimed.
The CPC nevertheless denied the exemption on the ground that registration was not available. In Abhinay Taranga Trust v. ITO, the Bengaluru ITAT held that the date on which final registration was granted could not, by itself, defeat the claim. It directed the Assessing Officer (AO) to allow the section 11 exemption after necessary verification in accordance with law.
The trust’s return and the CPC adjustment
Abhinay Taranga Trust was formed to impart education and training in performing arts, including drama, theatre, cinema and related cultural disciplines. It had obtained provisional registration covering AY 2024–25.
The trust filed its return for that year on 27 September 2024, declaring gross receipts of ₹16,49,220. It claimed ₹7,86,501 as corpus donations under section 11(1)(d) and exemption for the remaining ₹8,62,719 under section 11(1)(a). Its returned total income was therefore nil.
Want to Read the Complete Judgment?
You have read the free case summary. Unlock the full judgment, the detailed judicial reasoning and the downloadable PDF, along with every other premium judgment on TaxGuru.
Already subscribed? Log in
One subscription covers the entire premium judgment library, not just this case.
