This compilation indexes 12 rulings — spanning ITAT benches at Jodhpur, Jaipur, Rajkot, and Surat, and High Courts at Gauhati, Karnataka, Punjab-Haryana, Patna, and Allahabad — in which Section 13(1)(b) was a cited provision. Researchers should note that the provision appears in two entirely distinct legal instruments: Section 13(1)(b) of the Income-tax Act, 1961 (concerning restrictions on exemptions for charitable trusts that serve a particular religious community or caste), and Section 13(1)(b) of the Prevention of Corruption Act, 1988 (concerning criminal misconduct by a public servant). Both strands are represented in this index, and the applicable statute in each case is identifiable from the bench, parties, and sections engaged fields below.

Research index only. This page is a structured reference tool for legal and tax professionals. Nothing on this page constitutes legal or tax advice. Always verify rulings against the full judgment text and check for subsequent stays, reversals, or appellate developments before relying on any entry.

The statutory framework in one paragraph

Under the Income-tax Act, 1961, Section 13(1)(b) provides that nothing in Sections 11 and 12 shall operate to exclude from the total income of a previous year any part of the income of a trust or institution established for the benefit of any particular religious community or caste. This provision is a gateway disqualifier: where the CIT(Exemptions) finds that a trust's objects or activities are confined to serving a specific community or caste rather than the public at large, it may deny or revoke registration, rendering income otherwise eligible for exemption taxable. Separately, Section 13(1)(b) of the Prevention of Corruption Act, 1988 defines criminal misconduct to include a public servant who, without any public interest, obtains for himself or any other person any valuable thing or pecuniary advantage. These are distinct statutory provisions sharing only a common alphanumeric designation, and readers must identify the governing statute from context before drawing any interpretive parallel between the two groups of cases in this compilation.

The 12 rulings

1. Shree Digamber Jain Udasin Shravika vs CIT Exemption, Jaipur, Jaipur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 6 August 2026
Sections engaged: 115T, 12A, 13(1), 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 315/Jodh/2024, Assessment Year 2024-25) was filed before the ITAT Jodhpur against an order of the CIT(Exemptions), Jaipur. Per the source preview, the assessee had filed an online application in Form No. 10AB on 29.09.2023 seeking registration under section 12AB of the Act, following which the CIT(E) issued a notice dated 09.12.2023 calling for documents and explanations by 20.12.2023; the assessee sought an adjournment. The substantive outcome on the grounds raised — which engage Sections 115T, 12A, 13(1), and 13(1)(b) — is not specified in the available source preview.

2. Shri Namdev Samaj Sewa vs CIT(Exemption), Jaipur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 5 August 2026
Sections engaged: 11, 12A, 12A(1)(ac), 13(1)(b), 2(15)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 399/Jodh/2024, Assessment Year 2024-25) was filed before the ITAT Jodhpur against the CIT(Exemptions), Jaipur. Per the source preview, one of the substantive grounds taken by the assessee was that the CIT(Exemptions) grossly erred in holding the activities of the appellant trust to be non-genuine, which the assessee contended was contrary to the facts and objects of the charitable trust. The final outcome on those grounds is not specified in the available source preview.

3. Jain Citizen Foundation Trust, Jaipur vs CIT (Exemption), Jaipur, Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 28 July 2026
Sections engaged: 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 825 & 826/JPR/2026, Assessment Year 2026-27) was heard by the ITAT Jaipur Bench (A). Per the source preview, the assessee is a charitable trust registered under the Rajasthan Societies Registration Act, 1958, engaged in activities including relief to the poor, education, medical relief, and advancement of objects of general public utility. Notably, the source preview records that this was the second round of appeal, the matter having been previously remanded by the Tribunal in ITA No. 276 and 193/JP/2025 dated 28.10.2025 back to the CIT(E); the final outcome of the second-round hearing is not specified in the available source preview.

4. Ranjit Das vs The Central Bureau Of Investigation

Bench: Gauhati High Court
Date: 14 July 2026
Sections engaged: 13(1)(b), 13(1)(e), 13(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This criminal petition (Crl.Pet./1416/2024) was filed before the Gauhati High Court (High Court of Assam, Nagaland, Mizoram and Arunachal Pradesh). Per the source preview, the matter involves the Central Bureau of Investigation, Anti Corruption Branch, Assam, with the case citation 2026:GAU-AS:9588. The sections engaged — 13(1)(b), 13(1)(e), and 13(2) — are provisions of the Prevention of Corruption Act, 1988, and the final outcome of the petition is not specified in the available source preview.

5. Sardar Sarfaraz Khan vs State By Lokayukta Police

Bench: Karnataka High Court
Date: 1 July 2026
Sections engaged: 13(1)(b), 13(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No. 4307 of 2026, GM-RES) was filed before the Karnataka High Court at Bengaluru. Per the source preview, the petitioner prayed to quash FIR in Crime No. 63/2025 dated 23.12.2025 registered by the Karnataka Lokayukta Police, Bengaluru, based on a source report dated 01.12.2025, for alleged offences punishable under Sections 13(1)(b) read with 13(2) of the Prevention of Corruption Act, 1988, pending before the XXIII Additional City Civil and Sessions Judge, Special Court, Bengaluru. The outcome of the writ petition is not specified in the available source preview.

6. Dawoodi Bohra Dargah Masjid And vs CIT(Exemption), Ahmedabad

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 15 April 2026
Sections engaged: 12A, 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 63/RJT/2025, Assessment Year 2025-26) was filed before the ITAT Rajkot Bench. Per the source preview, the appeal was accompanied by an application for condonation of a 5-day delay in filing, the assessee contending that it was unaware of the show cause notice issued by the CIT(E), Ahmedabad, since the notice was issued without the assessee's knowledge; the appeal was directed against a rejection order dated 23.11.2024. The substantive outcome is not specified in the available source preview.

7. M/S Shambhavi Groups vs Kotak Mahindra Bank Limited

Bench: Karnataka High Court
Date: 25 March 2026
Sections engaged: 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No. 9452 of 2026, GM-DRT) was filed before the Karnataka High Court at Bengaluru under Articles 226 and 227 of the Constitution of India, praying to quash an impugned order dated 16.03.2026 passed in Criminal Miscellaneous Petition No. 1730/2026 by the VI Additional Chief Judicial Magistrate at Bangalore. Per the source preview, the respondent is Kotak Mahindra Bank Limited; the precise legal context in which Section 13(1)(b) is engaged, and the final outcome of the petition, are not specified in the available source preview.

8. Bikram Singh Majithia vs State Of Punjab

Bench: Punjab-Haryana High Court
Date: 4 December 2025
Sections engaged: 13(1)(b), 13(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This petition (CRM-M-51341-2025) was filed before the Punjab-Haryana High Court at Chandigarh seeking regular bail. Per the source preview, the FIR in question is FIR No. 22 dated 25.06.2025, registered under Sections 13(1)(b) read with 13(2) of the Prevention of Corruption Act, 1988 as amended by the Prevention of Corruption (Amendment) Act, 2018, at Police Station Vigilance Bureau, FS-1, S.A.S. Nagar; the FIR was lodged on the basis of a report dated 07.06.2025. The outcome of the bail petition is not specified in the available source preview.

9. Prashant Kumar vs The State Of Bihar Through The

Bench: Patna High Court
Date: 21 November 2025
Sections engaged: 13(1)(b), 120B
Outcome: Outcome not specified in source
Procedural / substantive ground: This criminal miscellaneous petition (No. 26158 of 2025, arising out of PS Case No. 15, Year 2022, Thana-Vigilance, District-Patna) was filed before the Patna High Court. Per the source preview, the matter involves the State of Bihar through the Additional Chief Secretary, Vigilance Department, and multiple senior officers of the Special Vigilance Unit, Patna, as opposite parties. The sections engaged — 13(1)(b) and 120B — indicate proceedings under the Prevention of Corruption Act, 1988 alongside a criminal conspiracy provision; the final outcome is not specified in the available source preview.

10. Haji Pir Mohmad Yusuf Waqf, Surat vs CIT(Exemption), Ahmedabad

Bench: Income Tax Appellate Tribunal - Surat
Date: 15 October 2025
Sections engaged: 12A, 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1326/SRT/2024) was filed before the ITAT Surat Bench against an order of the CIT(Exemptions), Ahmedabad. Per the source preview, the appeal emanates from the CIT(E)'s order dated 23.11.2024 rejecting the assessee's application for registration of the trust under section 12AB of the Income-tax Act, 1961; the assessee had filed an application for registration, and the rejection gave rise to the present appeal. The substantive outcome is not specified in the available source preview.

11. Shree Soni Nyat Samast Vadi, Dwarka vs The Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 9 July 2024
Sections engaged: 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 277/RJT/2019, Assessment Year 2019-20) was filed before the ITAT Rajkot Bench against the order of the Commissioner of Income Tax (Exemption), Ahmedabad. Per the source preview, the appeal was directed against an order under Section 12AA(1)(b)(ii) of the Income-tax Act, 1961 wherein the application filed by the assessee in Form No. 10A for approval under Section 12AA was rejected on the ground that the trust was created for a particular community/caste, that is, "Soni Nyat." The final outcome is not specified in the available source preview.

12. Amresh Yadav vs State Of U.P. And Another

Bench: Allahabad High Court
Date: 3 July 2024
Sections engaged: 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: This bail application (Criminal Misc. Bail Application No. 12143 of 2023, Neutral Citation No. 2024:AHC:107543) was filed before the Allahabad High Court. Per the source preview, the applicant sought enlargement on bail in Case Crime No. 1364 of 2020, registered under Sections 13(1)(b) and 13(2) of the Prevention of Corruption Act, 1988, Police Station-Cantt., District-Gorakhpur, during the pendency of Special Case No. 441 of 2023 before the Additional District and Sessions Judge/Special Judge (PC Act), Court No. 1, Gorakhpur; an FIR dated 04.12.2020 was lodged by Ram Dhari Mishra, Inspector, Anti-Corruption Organization, U.P., and the applicant was nominated as the sole named accused. The outcome of the bail application is not specified in the available source preview.

Patterns across these 12 rulings

Dual-statute character of the section reference. The designation "Section 13(1)(b)" spans two entirely different statutes in this dataset: the Income-tax Act, 1961 (charitable trust exemption restriction) and the Prevention of Corruption Act, 1988 (criminal misconduct by public servants). Researchers retrieving cases by section number alone must verify the governing statute in each instance; the two legal contexts are substantively unrelated.
Charitable trust registration denials as a recurring ITAT theme. Cases 1, 2, 3, 6, 10, and 11 all involve ITAT appeals against CIT(Exemptions) orders rejecting or declining to grant registration to trusts under Sections 12A or 12AB. In several of these cases, the community-specificity question — the core concern of Section 13(1)(b) of the IT Act — appears as the underlying reason cited by the revenue authority for denial.
Form No. 10AB / 10A filing and procedural notice disputes. In at least two of the income-tax cases in this dataset (cases 1 and 10), the source preview discloses that the assessee had filed an application in Form No. 10AB (or 10A) for registration under Section 12AB (or 12AA), and the CIT(E) issued a show cause notice to which the assessee responded; in case 6, the assessee raised a condonation of delay argument on the ground of non-receipt of the show cause notice. This suggests procedural notice-compliance issues are a distinct sub-theme within this group of ITAT cases.
Bail and FIR-quashing petitions dominate the High Court strand. Among the High Court cases (cases 4, 5, 8, 9, and 12), the dominant procedural posture is either a bail application or a writ petition seeking to quash an FIR, all in the context of Prevention of Corruption Act proceedings. No substantive merits ruling on corruption charges is visible in the source previews available for this compilation.
Outcomes uniformly unspecified across all 12 cases. Across every entry in this dataset, the outcome is recorded as "Outcome not specified in source." This is a structural limitation of the available source previews rather than a pattern in the underlying law; users should retrieve the full judgment text from indiankanoon.org or official court portals to determine the operative holding in each case.

How to use this compilation

This index is designed as a starting point for legal and tax research, not as a substitute for reading the full judgment. Each entry identifies the forum, date, and sections engaged so that researchers can quickly triage which rulings are relevant to their query. However, because source previews in this compilation are truncated — and because outcomes are uniformly recorded as unspecified — no entry in this index should be cited as authority for any proposition without first retrieving and reading the complete order from the original court portal or indiankanoon.org.

Researchers should also check for subsequent developments in each case. An ITAT order may have been appealed to the High Court; a High Court bail order may have been challenged before the Supreme Court; a trust registration matter decided at the ITAT level may be the subject of a fresh filing in a subsequent assessment year. The date of pronouncement listed in each entry reflects only the order indexed here, not the full litigation history of the underlying dispute.

Finally, given that "Section 13(1)(b)" appears in two unrelated statutes, researchers should apply filters beyond the section number when building a research set. For income-tax exemption matters, additional filters such as "CIT(Exemptions)," "12A," "12AB," or "trust registration" will narrow results to the IT Act strand. For corruption proceedings, filters such as "Prevention of Corruption Act," "Lokayukta," "CBI," or "Vigilance" will isolate the PC Act strand. Cross-referencing CBDT circulars and instructions on trust registration procedures may also assist in understanding the administrative framework within which the income-tax cases in this compilation arise.

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 13(1)(b) — Income Tax & PC Act: 12 Rulings (2024–2026)