This compilation indexes twelve income-tax rulings — spanning ITAT benches at Hyderabad, Mumbai, Amritsar, Chandigarh, Cuttack, Vizag, and Agra, as well as the Bombay High Court and Gujarat High Court — in which Section 11(2) of the Income Tax Act, 1961 was a central or co-examined provision. The rulings span February 2025 to July 2026. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a single reference point for recent judicial activity around the accumulation-of-income exemption available to charitable and religious trusts. Case 9 (Bhagyavathy vs Thomas Jacob @ Jinu, Kerala High Court, 31 July 2025) has been retained in its indexed slot; however, the source preview for that matter discloses civil property-dispute proceedings before the Sub Court, Kattappana and the Munsiff's Court, Peerumedu, with no substantive income-tax content visible in the available text. It is therefore noted with a process observation only.

Research index only. This page reproduces publicly available case data for reference purposes. Nothing here constitutes legal advice, tax advice, or a recommendation of any course of action. Verify every ruling against the full judgment text and check for subsequent stays, reversals, or appeals before relying on it.

The statutory framework in one paragraph

Section 11(2) of the Income Tax Act, 1961 provides that where eighty-five per cent of the income of a trust or institution as referred to in Section 11(1) is not applied to charitable or religious purposes in India during the previous year, the trust or institution may accumulate or set apart such income for application to such purposes for a period not exceeding five years, provided certain conditions are satisfied — principally that the trust furnishes a notice in the prescribed form (Form No. 10) to the Assessing Officer specifying the purpose for which the income is being accumulated and the period over which it is to be so accumulated, and that such income is invested or deposited in the modes specified in Section 11(5). Non-compliance with these procedural and substantive requirements — including vagueness in stating the purpose in Form No. 10 — has been a recurring ground for disallowance of the accumulation claim by revenue authorities.

The 12 rulings

1. Medak Catholic Mission,Hyderabad vs ITO., Exemption Ward-1(2), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 15 July 2026
Sections engaged: 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the assessee before the Income Tax Appellate Tribunal, Hyderabad ('B' Bench) bearing ITA No. 1234/Hyd/2025 for Assessment Year 2018-19, and was directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 30.05.2025. The source preview confirms the matter involves Medak Catholic Mission (PAN: AAATM 2443 D) and that the appeal arose from proceedings under Section 11(2); substantive reasoning is not reproduced in the available text preview.

2. Jeevan Jyot Cancer Relief & Care Tust vs ITO - Exem. Ward 1(4), Mumbai, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 7 July 2026
Sections engaged: 11(2), 129, 12A, 142(1), 143(2), 143(3), 250, 288A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal by the assessee (ITA No. 4506/Mum/2026, PAN: AAATJ2299Q) for Assessment Year 2016-17 was directed against the order dated 26.08.2025 passed by the CIT(A), NFAC, Delhi under section 250, which arose from the assessment order dated 13.12.2018 passed by the Assessing Officer under section 143(3). The assessee raised grounds of appeal contending, among other things, that non-attendance or non-reply during proceedings was for reasons not attributable to the appellant and beyond its control; the full substantive reasoning on the Section 11(2) issue is not reproduced in the available text preview.

3. D.L.Shah Trust For Applied Science vs Income Tax Officer (Exemp) - 1(2)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 June 2026
Sections engaged: 11(2), 11(3)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals — ITA Nos. 8 & 446/MUM/2026 — were filed by the assessee (PAN: AAATD0131B) for Assessment Years 2013-14 and 2015-16 against orders of the National Faceless Appeal Centre, Delhi / CIT(A) commonly dated 05-Dec-2025. Since the issues in both appeals were stated to be common and identical and belonged to the same assessee, the bench clubbed them, heard them together, and passed a consolidated order; substantive findings on the sections engaged are not reproduced in the available text preview.

4. Kishan Dham Charitable Trust ,Kishan vs Income Tax Officer , Exemption Ward

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 5 May 2026
Sections engaged: 11(2), 12A, 154
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee is a charitable trust registered with the Registrar of Societies since 1994 and registered under section 12A since 1995 and under Section 80G since 2009. The return for AY 2014-15 (ITA No. 399/Asr/2024, PAN: AAATK0778P) was filed in ITR-7 on 22/12/2014, claiming exemption under Section 11, disclosing income at NIL; it was revised on 08/10/2015 in response to a deficiency notice dated 21/08/2015, and was initially processed under Section 143(1) by CPC, Bangalore, on a total income of Rs. 22.92 lakhs, refusing the exemption claim under Section 11. The appeal before the Amritsar Bench arose in this context; further substantive findings are not reproduced in the available text preview.

5. Commissioner Of Income Tax Exemptions vs Impact Foundation India Ay 2017-18

Bench: Bombay High Court
Date: 4 May 2026
Sections engaged: 263, 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the Revenue (Income Tax Appeal No. 126 of 2024) under Section 260A of the Income Tax Act, 1961 before the Bombay High Court, challenging the order dated 2nd January 2023 passed by the lower authority. The source preview indicates the CIT (Exemptions) invoked section 263, requiring that the order of the Assessing Officer be erroneous and that prejudice be caused to the interest of the revenue as dual conditions for revision; the dispute concerned an application involving accumulation of funds for specified purposes including urban and rural sanitation and strengthening of civil society in India. Full substantive findings on Section 11(2) are not reproduced in the available text preview.

6. Dinabandhu Foundation For Educational vs Additional/Joint/Deputy/Assistant

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 20 February 2026
Sections engaged: 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed a Stay Application along with appeal in ITA No. 450/CTK/2025 (PAN: AAATD 7338 L) for Assessment Year 2018-2019 against the order dated 21.07.2025 passed by the CIT(A), National Faceless Appeal Centre (NFAC), Delhi, which disallowed the exemption claimed by the assessee trust under Section 11(2) on the ground that the purpose mentioned in Form No. 10 was too vague and lacked the required specificity. The assessee's counsel submitted that the assessee had, during the impugned assessment year, filed its Form No. 10 with a stated purpose, and contested the revenue's position that the description was insufficiently specific.

7. Haryana Building And Other vs CIT(Exemption), Chandigarh

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 10 December 2025
Sections engaged: 11(2), 11(3)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: Multiple appeals were filed by Haryana Building and Other Construction Workers Welfare Board (PAN: AAATH6995H) covering Assessment Years 2014-15, 2015-16, 2016-17, 2017-18, and 2018-19 (ITA Nos. 237/CHD/2020, 63/CHD/2021, and 337 to 339/CHD/2023). The appeals arose from orders of CIT(A)-1, Chandigarh and CIT(A), NFAC, Delhi at various dates; certain of the appeals were noted as delayed by one day. Substantive findings on the sections engaged are not reproduced in the available text preview.

8. Ap Pollution Control Board,Vijayawada vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Vizag
Date: 6 August 2025
Sections engaged: 10(46), 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 298/Viz/2025, PAN: AAAJA1610Q) for Assessment Year 2021-22 was directed against the revision order dated 11/03/2025 passed by the CIT (Exemptions) under Section 263. The assessee, Andhra Pradesh Pollution Control Board, is a statutory body that was granted approval under Section 10(23C) of the Act dated 29/09/2010 and had subsequently applied for notification under Section 10(46); the appeal engaged both Section 10(46) and Section 11(2) in the context of those alternate exemption claims. Full substantive findings are not reproduced in the available text preview.

9. Bhagyavathy vs Thomas Jacob@ Jinu

Bench: Kerala High Court
Date: 31 July 2025
Sections engaged: 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (RSA No. 425 of 2025) was filed before the High Court of Kerala at Ernakulam against the judgment and decree dated 29.03.2025 in AS No. 33 of 2021 of the Sub Court, Kattappana, itself arising out of OS No. 20 of 2013 of the Munsiff's Court, Peerumedu. The source preview discloses civil property-dispute proceedings involving individual parties; no income-tax or Section 11(2) substantive content is visible in the available text preview, and the matter appears to be a civil second appeal. This entry is retained as indexed but researchers should independently verify whether Section 11(2) was substantively engaged in this proceeding.

10. Odisha Sports Development vs DCIT, Exemption Ward, Bhubaneswar

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 8 April 2025
Sections engaged: 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee (ITA Nos. 496-498/CTK/2024, PAN: AABCO 9237 H) for Assessment Years 2015-16, 2016-17, and 2017-18 is a company promoted by the Government of Odisha whose accounts were audited by statutory auditors. The assessee's counsel submitted that the return of income was filed on 31.03.2017 and that Form 9A had been filed; the matter was heard through virtual hearing before the Cuttack Bench. Substantive findings on Section 11(2) are not reproduced in the available text preview.

11. Brahmchari Wadi Trust vs Commissioner Of Income Tax (Exemption)

Bench: Gujarat High Court
Date: 17 March 2025
Sections engaged: 119(2)(b), 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: By this petition under Article 227 of the Constitution of India (R/Special Civil Application No. 24687 of 2022), the petitioner prayed for quashing and setting aside the order dated 19.12.2019 passed under section 119(2)(b) of the Act. The Gujarat High Court noted that the issue involved was in a very narrow compass and, with the consent of advocates for both parties, took the matter up for hearing; Rule was made returnable forthwith and notice was waived by the respondent's counsel. The petition connects the section 119(2)(b) condonation issue to the underlying Section 11(2) accumulation claim; substantive holdings are not reproduced in the available text preview.

12. Omkar Memorial Charitable Society vs CIT[Exemption], Bhopal

Bench: Income Tax Appellate Tribunal - Agra
Date: 27 February 2025
Sections engaged: 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 160/AGR/2024, PAN: AAAA08054B) was heard through virtual hearing. The assessee is a charitable society that was granted provisional registration and subsequently made an application in the prescribed format seeking permanent registration under Section 12AB. The CIT (Exemptions) passed an order in Form 10AD rejecting the application for permanent registration on the ground that the assessee does not possess the registration for running certain activities; the source preview links this registration dispute to the Section 11(2) exemption claim. Full substantive findings are not reproduced in the available text preview.

Patterns across these 12 rulings

Form No. 10 specificity as a recurring dispute trigger. The Cuttack Bench in Dinabandhu Foundation (case 6) explicitly records that the CIT(A)/NFAC disallowed the Section 11(2) claim on the ground that the purpose stated in Form No. 10 was too vague and lacked the required specificity. This mirrors a pattern visible across several other matters in this set where the adequacy of the Form No. 10 purpose-statement appears to be the operative question.
Multi-year consolidated appeals. The D.L. Shah Trust matter (case 3) involved two assessment years consolidated into a single order, and the Haryana Building and Other Construction Workers Welfare Board matter (case 7) covered five assessment years across multiple ITA numbers. Consolidation of Section 11(2) disputes across years for a single assessee appears to be a common procedural feature at the ITAT level.
NFAC orders as the immediate impugned order. Across cases 1, 2, 3, 4, 6, and 10, the immediate order being challenged before the ITAT was passed by the National Faceless Appeal Centre (NFAC), Delhi. This reflects the operational reality that NFAC now serves as the first appellate forum for most exemption-related assessments, and Section 11(2) disputes routinely proceed from NFAC orders to ITAT benches.
Section 263 revision as an alternate revenue route. In both the Bombay High Court matter (case 5, Commissioner of Income Tax Exemptions vs Impact Foundation India) and the Vizag ITAT matter (case 8, AP Pollution Control Board), the immediate proceedings arose from revision orders rather than from direct assessment orders. This suggests that revenue authorities have in some instances invoked the revisionary power to re-examine Section 11(2) claims after the original assessment.
Section 119(2)(b) condonation linked to Section 11(2) filings. The Gujarat High Court matter (case 11, Brahmchari Wadi Trust) involves a petition challenging an order passed under section 119(2)(b), which on the available preview appears to be connected to a condoning of delay in filing documents relevant to the Section 11(2) accumulation claim. The intersection of the condonation provision and the accumulation exemption represents a distinct procedural dimension that appears in this corpus.

How to use this compilation

This index is a starting point for locating recent judicial activity on Section 11(2) and related provisions. Each entry provides the bench, date, sections engaged, and outcome direction exactly as recorded in the source data, together with a brief note drawn only from the available text preview for that specific case. Because the text previews are excerpts and do not reproduce full operative paragraphs or final dispositive directions, researchers must obtain and read the complete judgment text before drawing any conclusions about the holding, ratio, or applicability of a ruling. Full texts of ITAT orders are available on the ITAT e-filing portal and on indiankanoon.org; High Court judgments are available on the respective court portals and on indiankanoon.org.

Before citing any ruling from this compilation in a filing, opinion, or submission, researchers should verify: (a) whether the order has been subsequently stayed, reversed, or modified in further appeal; (b) whether a Special Leave Petition or writ petition has been filed against the order; and (c) whether any CBDT circular, notification, or instruction has been issued that bears on the same procedural or substantive point. CBDT instructions on Form No. 10, accumulation periods, and the modes of investment under Section 11(5) are periodically updated and may affect the analysis.

Finally, note that several entries in this compilation record "Outcome not specified in source" because the dispositive tail or operative paragraph was not fully reproduced in the available text preview. This does not mean the case was undecided — it means the outcome cannot be stated with certainty from the indexed excerpt alone. Treat such entries as leads to the full judgment rather than as summaries of holdings.

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(2) Income Tax Exemption: 12 ITAT & HC Rulings (2025–2026)