Where the assessee-trust purchased land out of trust funds originally contributed by the trustees, but the sale deeds were mistakenly registered in the names of the trustees, and the facts showed that the property was used exclusively for running the school without any benefit accruing to the trustees, section 13(1)(c) was not applicable.

3. (2026) 184 taxmann.com 22 (Chennai Trib)

ACIT vs. Everwin Educational & Charitable Trust

A.Y.: 2016-17 Date of Order: 24.02.2026

Section : 13(1)(c), 13(2)(g)

Where the assessee-trust purchased land out of trust funds originally contributed by the trustees, but the sale deeds were mistakenly registered in the names of the trustees, and the facts showed that the property was used exclusively for running the school without any benefit accruing to the trustees, section 13(1)(c) was not applicable.

FACTS

The assessee was a public charitable trust holding registration under section 12A/12AB. For AY 2016-17, it filed the return of income after claiming exemption under section 11. During the year, the trustees had settled two schools, which they were operating in their individual capacity since 1992, along with assets, liabilities and cash balances of about Rs. 19.49 crores, upon the assessee-trust with effect from 1.4.2015. Out of these funds, the trust purchased land parcels worth about Rs. 14.70 crores for establishing a school; however, due to a misunderstanding and bona fide omission, the sale deeds were executed in the na