Karnataka Samarpana Education Society Vs CIT (Exemptions) (ITAT Bangalore)
Running Schools Does Not Make a Society “Charitable Only”: ITAT Directs Fresh Examination of Religious Objects
A society’s educational activities do not, by themselves, determine how it should be described in its Section 12AB registration. Where the application and governing documents disclose religious as well as charitable objects, the Commissioner of Income Tax (Exemptions) must examine that claim before recording the society as purely charitable. This is the principle emerging from the Bengaluru ITAT’s order in Karnataka Samarpana Education Society v. CIT(E), ITA No. 1439/Bang/2026, pronounced on 29 September 2026.
Registration Was Granted, but the Description Was Disputed
The society had applied in Form 10AB on 29 September 2025. The CIT(E), by order dated 17 January 2026, granted registration under Section 12AB for AYs 2027–28 to 2031–32. Thus, the appeal did not concern a refusal of registration. The society’s grievance was narrower: although it had sought recognition as a religious-cum-charitable institution, the registration described it as charitable.
The society argued that this was inconsistent with its application, its objects, its note on activities and the supporting records. It also pointed out that the CIT(E)’s order contained no finding rejecting its religious objects or activities. In its view, an incorrect description could matter when the provisions governing its exemption are applied in later years.
