This compilation indexes twelve adjudicated matters — spanning ITAT benches across Bangalore, Pune, Hyderabad, Ranchi, Jodhpur, Cuttack, Ahmedabad, and the Bombay and Himachal Pradesh High Courts — in which Section 11(1)(a) of the Income Tax Act, 1961 formed a central or co-primary ground of dispute. The cases span the period December 2022 to July 2026 and involve a range of entities: educational trusts, charitable societies, statutory port authorities, and religious trusts. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who require a structured, citeable starting point for primary-source research on the exemption framework for charitable and religious institutions.

Disclaimer: This page is a research index only. Nothing herein constitutes legal or tax advice. Readers must verify all rulings against full, authoritative judgment texts and check for any subsequent stays, reversals, or legislative amendments before relying on any entry.

The statutory framework in one paragraph

Section 11(1)(a) of the Income Tax Act, 1961 provides that income derived from property held under trust wholly for charitable or religious purposes shall not be included in the total income of the person in receipt thereof, to the extent that such income is applied to such purposes in India — and, where any such income is accumulated or set apart for application to such purposes in India, to the extent that the income so accumulated or set apart does not exceed fifteen per cent of the income from such property. The provision is the primary operative exemption for registered charitable and religious institutions and operates in conjunction with the registration requirements under related provisions of the Act.

The 12 rulings

1. Mite Foundation For Innovation vs CIT(Exemptions) Bangalore, Bangalore

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 31 July 2026
Sections engaged: 11(1)(a), 12A, 80G
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 271 & 276/Bang/2026) were filed by the assessee against separate orders of the CIT (Exemptions) Bangalore, both dated 12.11.2025, bearing DIN & Notice No. ITBA/EXM/F/EXM45/2025-26/1082554706(1). Per the source preview, the CIT (Exemptions) raised objections including that no Activity Report had been furnished and no copy of Darpan registration had been submitted by the assessee.

2. Crescent India Medical Education Trust vs AO/Dy CIT, Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 2 July 2026
Sections engaged: 11(1)(a), 144B(7)(vii)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No.2546/PUN/2025) was filed by the assessee against the order of the CIT(A), NFAC, passed for AY 2023-24 on 14.10.2025, emanating from an assessment order dated 11.03.2025. Per the source preview, the assessee's AR admitted before the tribunal that the assessee had not taken the requisite permission from the Income Tax Department, and the assessee acknowledged this as an inadvertent mistake; the assessee had filed a revised statement of income and suo-moto disallowed Rs.50,00,000/-.

3. Jamia Osman Bin Affan Education vs ITO., Exemption Ward-1(2), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 13 May 2026
Sections engaged: 11(1)(a), 12A
Outcome: Outcome not specified in source
Procedural / substantive ground: These appeals (ITA Nos. 477 & 631/Hyd/2024) were filed by Jamia Osman Bin Affan Education Society against separate orders of the CIT(A), NFAC, Delhi, dated 27.03.2024 for A.Y. 2017-18, and the order of the CIT (Exemption), Hyderabad, dated 06.06.2024. Per the source preview, the appeals arose from the same assessee and involved inter-related issues; the tribunal noted they were taken up together for convenience.

4. ACIT, Exemption Circle, Ranchi vs M/S. R.V.S. Educational Trust

Bench: Income Tax Appellate Tribunal - Ranchi
Date: 21 May 2025
Sections engaged: 11(1)(a), 2(15)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No.24/RAN/2020) pertained to A.Y. 2016-2017 and was filed by the Revenue against RVS Educational Trust (PAN: AAATR4456M). Per the source preview, the assessee operated multiple units including R.V.S. International School, R.V.S. Academy, and R.V.S. Hostel; financial figures referenced in the preview include total amounts of Rs.4,39,31,321/- and Rs.69,66,832/-, and the CIT's order dated 5.12.2019 had confirmed certain disallowances of Rs.1,70,87,735/- while deleting others.

5. ACIT., Exemptions Circle-1(1) vs Pharmaceuticals Export Promotion

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 11 February 2025
Sections engaged: 11(1)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No.1199/Hyd/2024) was filed by the Revenue against the order of the CIT(A), NFAC Delhi, dated 30.08.2024, for AY 2016-17. Per the source preview, the assessee (PAN: AADCP4643C) is a society registered under the relevant provisions of the Income Tax Act since 09-11-2006; it had e-filed its return of income for A.Y. 2016-17 on 12-10-2016 declaring NIL income, and the case was selected for scrutiny under CASS with notices issued accordingly.

6. The Shri Saibaba Sansthan Trust vs The Union Of India And 3 Ors

Bench: Bombay High Court
Date: 20 December 2024
Sections engaged: 11(1)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter came before the Bombay High Court as Writ Petition No. 4817 of 2022, filed by The Shri Saibaba Sansthan Trust (Shirdi), a trust constituted under the Shri Saibaba Sansthan (Shirdi) Act, 2004, against the Union of India and officers of the Income Tax (Exemptions) wing. Per the source preview, the petition engaged the framework governing assessments and exemptions, with the court's order running to 43 pages; the substantive grounds from the full text are not sufficiently detailed in the preview to summarise further.

7. Vidhya Pracharini Sabha,Udaipur vs ACIT Exemption Circle,, Jodhpur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 12 November 2024
Sections engaged: 11(1)(a), 143(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 19/Jodh/2024) concerned Assessment Year 2016-17. Per the source preview, objections raised during proceedings included that Form 10B was not provided during survey, that there were questions about how the institution came to know of the set apart amount on 05/03/2016 without preparing a balance sheet, and that the survey record suggested a relevant resolution was in question.

8. Paradip Port Authority, Jagatsinghpur vs DCIT,Circle-1(1), Cuttack

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 25 September 2024
Sections engaged: 11(1)(a), 263
Outcome: Outcome not specified in source
Procedural / substantive ground: These appeals (ITA Nos. 208-210/CTK/2024) covered Assessment Years 2003-2004 to 2005-2006 and were filed by Paradip Port Authority (PAN: AAALP0055A). Per the source preview, similar and identical grounds were raised in all three appeals; the assessee challenged an order on the ground that the order passed dated 10-10-2022 was not prejudicial to the interest of the revenue, thereby disputing whether the mandatory cumulative condition stipulated under the relevant provision was satisfied.

9. Unknown vs The Tibetan Children'S Village Dal Lake

Bench: Himachal Pradesh High Court
Date: 22 August 2023
Sections engaged: 11(1)(a), 147
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised a batch of appeals before the Himachal Pradesh High Court at Shimla, including ITA No.28 of 2019, ITA No.29 of 2019, and ITA No.1 of 2020, filed by the Commissioner of Income Tax (Exemptions), Chandigarh, against The Tibetan Children's Village Dal Lake, Dharamshala Cantt. (H.P.) (PAN-AAATT3933B). The appeals were reserved on 07.08.2023 and decided on 22.08.2023; further substantive detail is not available from the source preview.

10. The DCIT (Exemptions), Circle-2 vs Ahmedbad Urban Development Authority

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 26 July 2023
Sections engaged: 11(1)(a), 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: These were cross appeals (ITA No. 1736/Ahd/2019 and ITA No. 4/Ahd/2020) filed by the assessee and the Department respectively, both for Assessment Year 2016-17 (PAN: AAALA0233B), against the order of the Commissioner of Income Tax (Appeals). Per the source preview, the appeals were heard on 18-07-2023 and the order was pronounced in open court on 26-07-2023; further substantive detail on the grounds is not available from the source preview.

11. Anand Mercantile Samaj Seva Trust vs The ITO (Exemption), Vadodara

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 31 May 2023
Sections engaged: 11(1)(a), 11(2), 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: These appeals (I.T.A. Nos. 273 & 274/Ahd/2021) related to Assessment Years 2016-17 and 2017-18 for the assessee (PAN No. AAATA2667F). Per the source preview, the income and expenditure figures referenced include a gross total income of Rs.2,52,83,936/-, with an amount applied for charitable purpose of Rs.1,41,02,264/- and an assessed income of Rs.2,00,00,000/-; the assessee challenged findings of the CIT(A), NFAC on grounds of error in law and/or on facts.

12. Deputy Commissioner Of Income-Tax vs Maharashtra Education Society,, Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 5 December 2022
Sections engaged: 11(1)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: These were cross appeals (ITA No.1408/PUN/2019 and ITA No.1577/PUN/2019) filed by the assessee and the Revenue for Assessment Year 2015-16, directed against the order of the CIT(A)-10, Pune, dated 16.07.2019. Per the source preview, during the course of hearing, the assessee's AR did not press the grounds of appeal; accordingly, the tribunal dismissed the assessee's appeal as not pressed, and the Revenue's appeal on the substantive grounds arising from the assessment proceeded separately.

Patterns across these 12 rulings

Charitable and religious entities are the dominant litigants. Across all twelve cases, the assessee is either an educational trust, a charitable society, a religious sansthan, or a statutory authority claiming exemption status — reflecting the core constituency of Section 11(1)(a) litigation before ITAT and High Courts.
Registration compliance (Section 12A) appears alongside Section 11(1)(a) disputes. In at least two cases (Case 1: Mite Foundation; Case 3: Jamia Osman Bin Affan), Section 12A featured alongside Section 11(1)(a), indicating that procedural compliance with registration requirements is a recurring point of contest that arises contemporaneously with substantive exemption claims.
Cross appeals (assessee and Revenue both challenging the same CIT(A) order) are a recurring procedural feature. Cases 10, 11, and 12 explicitly involve cross appeals, suggesting that CIT(A) orders in this space frequently leave both sides partially aggrieved, prompting concurrent appeals to the ITAT.
NFAC orders feature prominently as the upstream order under challenge. In Cases 2, 3, 5, and 11, the order under challenge before the ITAT was passed by the CIT(A), NFAC, Delhi — reflecting the faceless appeals regime's integration into the standard litigation pathway for exemption-related disputes.
Source previews across all twelve cases do not reveal final dispositive outcomes. Every entry carries the outcome field "Outcome not specified in source," indicating that while the orders have been pronounced and the proceedings are complete, the structured corpus does not yet capture the dispositive direction for this batch. Researchers should access the full text of each judgment for the operative findings and relief granted or denied.

How to use this compilation

This compilation functions as a structured discovery index, not a substitute for primary-source research. Each entry provides the ITA or Writ Petition number, bench, date of pronouncement, and sections engaged — sufficient to locate the full judgment on indiankanoon.org, the official ITAT e-filing portal, or the respective High Court's online repository. Researchers should retrieve and read the complete order before drawing any conclusion about the ratio, the operative holding, or the relief granted, as the source previews reproduced here are necessarily partial.

Before relying on any ruling in advisory or litigation work, researchers should verify whether the order has been challenged in a higher forum, whether a stay has been granted against it, and whether any subsequent Supreme Court or High Court decision has overtaken the legal position applied by the tribunal. ITAT orders, in particular, are frequently subject to appeal under Section 260A before the jurisdictional High Court, and High Court orders may be further appealed by special leave.

Researchers should also cross-check the CBDT's circulars and instructions in force at the relevant assessment year, as administrative guidance on the interpretation and application of exemption provisions evolves independently of judicial pronouncements and may affect the practical operation of any ruling indexed here.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 11(1)(a) Income Tax Exemption: 12 ITAT & HC Rulings (2022–2026)