The Court held that the very purpose of registration u/s 12AA is to enable a trust to claim exemption u/s. 10 and 11, but mere registration does not automatically entitle the trust to such exemption; the assessee must adduce cogent material before the CIT to establish that its activities are genuinely charitable, and the AO must verify such claim while assessing. The Court refused to doubt the correctness of Ananda Social & Educational Trust v. CIT (2020) 313 CTR (SC) 369 and declined reference to a Larger Bench.
CIT (E) v. International Health Care Education & Research Institute (2025) 343 CTR 273 / 247 DTR 273 / 304 Taxman 265 / 482 ITR 287 (SC).Editorial : CIT v. International Health Care Education and Research Institute (2025) 171 taxmann.com 578 ( Raj ) ( HC) affirmed.
S. 12AA : Procedure for registration-Mere registration under S. 12AA automatically does not entitle a charitable trust to claim exemption under ss. 10 and 11-AO has to verify genuineness of claim-Reference to Larger Bench declined-SLP of Revenue dismissed [S. 10, 11, Art. 136]