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November 2026

Rana Educational Trust v. ITO: Exemption denial under Section 11 does not justify taxing entire gross receipts without deducting legitimate expenses.

By Jagdish T Punjabi, Chartered Accountant Devendra Jain & Aditya Bhatt, Advocates
Reading Time 3 mins

63. (2026) 190 taxmann.com 512 (Chen Trib)

Rana Educational Trust v. ITO

A.Y.: 2024-25 Date of Order: 10.09.2026

Sections: 11, 12A, 143(1)

Where an educational trust, which lacked registration under section 12A and had not furnished the audit report in time, was denied exemption under section 11, the tax department could not tax its entire gross receipts without allowing legitimate and admission expenditure.

FACTS

The assessee, a trust running an educational institution, filed its return for A.Y. 2024-25 on 13.11.2024 in Form ITR-7, claiming exemption under section 11. It did not hold registration under section 12A for the year, and the audit report in the prescribed form had not been furnished within the time allowed.

The return was processed by the Centralised Processing Centre (CPC) under section 143(1). The CPC denied the exemption under section 11, and brought the entire receipts of Rs. 1,04,01,040 to tax, without allowing any deduction for expenditure.

On appeal, the CIT(A) upheld the stand of the CPC, noting that the audit report had not been furn

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