This compilation indexes twelve reported rulings — spanning the Income Tax Appellate Tribunal (ITAT), various High Courts, and the Supreme Court of India — in which Section 11(3) appears as a cited provision. The rulings range from 2016 to 2026 and arise across diverse factual contexts, including charitable trust exemptions, cooperative society disputes, arbitration appeals, and land-related proceedings. The compilation is intended as a structured starting point for tax researchers, in-house counsel, and professional associates who need to locate and cross-reference decisions touching this provision.

Research index only. This article is a structured case-law reference tool. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers must verify every ruling against the full authenticated judgment and consult qualified advisers before drawing any conclusions.

The statutory framework in one paragraph

Section 11(3) of the Income Tax Act, 1961 operates as a consequence provision within the charitable and religious trust exemption framework. In broad terms, where income accumulated or set apart by a trust or institution under Section 11(2) is applied for purposes other than those for which it was accumulated, or is invested in a manner not permitted, or ceases to be accumulated in accordance with the stated purpose within the specified period, such income is deemed to be the income of the trust or institution of the previous year in which it is so applied or misapplied. The provision is thus a clawback or deeming mechanism that can reverse the benefit of accumulation previously claimed. Because the section number "11(3)" also appears in several non-income-tax statutes — including state sales tax enactments, arbitration-related contexts, and cooperative society legislation — researchers should carefully verify the statutory context of each ruling before applying it to an income-tax matter.

The 12 rulings

1. Rohini Gupta And Anr vs District Deputy Registrar Coperative

Bench: Bombay High Court
Date: 8 September 2026
Sections engaged: 11(1), 11(3), 2(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Bombay High Court by petitioners described as original landowners, aggrieved by an order dated 23 June 2025 passed by the District Deputy Registrar, Co-operative Societies, Mumbai City-3, issuing a certificate of unilateral deemed conveyance of land admeasuring 3901.70 sq.m. in favour of Respondent No.3-Society. The matter was reserved on 25 August 2026 and pronounced on 8 September 2026; the source preview does not disclose the substantive outcome or the specific reasoning on the sections cited.

2. M/S G.H.Vijapura Infrastructure vs Executive Engineer Government Of

Bench: Madhya Pradesh High Court
Date: 25 June 2026
Sections engaged: 34, 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is an arbitration appeal filed by the claimant/contractor before the Madhya Pradesh High Court at Indore, being aggrieved by an order dated 13 September 2011 passed by the District Judge in Civil MJC No. 54/2007, whereby the respondent/State's application under Section 34 of the Arbitration and Conciliation Act, 1996 was allowed and the final award dated 8 September 2007 and interim award dated 6 November 2006 were set aside in substantial part, with only the portion relating to an additional right to operate the toll for 14 days being maintained. The source preview does not disclose the High Court's substantive ruling on the appeal or the basis on which the cited provisions were engaged.

3. Kapita Enclave Bldg. M Co-Op Housing vs Kiran Builders Pvt. Ltd

Bench: Bombay High Court
Date: 18 June 2026
Sections engaged: 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition was filed before the Bombay High Court by the developer/petitioner challenging an order dated 15 May 2017 passed by the District Deputy Registrar, Co-operative Societies-3, Mumbai, in a matter involving Kalpita Enclave Co-operative Housing Society Ltd. The matter was reserved on 11 June 2026 and pronounced on 18 June 2026; the source preview does not disclose the court's substantive findings or the specific basis on which the cited provision was engaged.

4. Yashwantrao Chavan Maharashtra Open vs Exemption Circle,A Bad, Aurangabad

Bench: Income Tax Appellate Tribunal - Pune
Date: 23 June 2025
Sections engaged: 11(3), 143(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.505/PUN/2025) was filed before the ITAT Pune Bench "B" by Yashwantrao Chavan Maharashtra Open University (YCMOU), PAN AAALY0016C, in respect of Assessment Year 2023-24. Per the source preview, YCMOU is established under the Yashwantrao Chavan Maharashtra Open University Act, 1989, with its sole object being education, and it has been primarily financed by the Government of Maharashtra; it was granted registration under Section 12AA by the CIT (Exemption), Pune vide letter dated 25 July 2016, with the registration subsequently renewed. The source preview does not disclose the ITAT's ultimate finding on the sections cited.

5. Dhyan Swamibapa Trust, Senjaldham vs The ITO Exemption, Ward-1, Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 14 June 2023
Sections engaged: 11(2), 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.244/Rjt/2022) was filed before the ITAT Rajkot (conducted through E-Court) by the assessee trust, PAN AAATD1598E, against the order of the CIT(Appeals), Rajkot, arising from an assessment order relevant to Assessment Year 2015-16. Per the source preview, the interconnected issue raised by the assessee was that the CIT(A) erred in confirming an adjustment made by the CPC; the source preview does not disclose the tribunal's substantive ruling on the sections cited.

6. Anand Mercantile Samaj Seva Trust vs The ITO (Exemption), Vadodara

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 31 May 2023
Sections engaged: 11(1)(a), 11(2), 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 273 & 274/Ahd/2021) were filed before the ITAT Ahmedabad "D" Bench by Anand Mercantile Samaj Seva Trust, PAN No. AAATA2667F, in respect of Assessment Years 2016-17 and 2017-18. The source preview records that the CIT(A), NFAC was alleged to have erred in law and/or on facts; it also records a gross total income figure of Rs. 2,52,83,936/-, an amount applied for charitable purpose of Rs. 1,41,02,264/-, and an assessed income of Rs. 2,00,00,000/- as reflected in the order extract. The source preview does not disclose the tribunal's substantive findings on the sections cited.

7. Shree Aniruddha Upasana Foundation vs CIT (Exemption) , Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 19 September 2022
Sections engaged: 263, 11(3), 13
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 706/MUM/2022) was filed before the ITAT Mumbai Bench "A" by Shree Aniruddha Upasana Foundation, PAN No. AAICS9217L, and was directed against a revision order dated 15 March 2022 passed by the CIT (Exemption), Mumbai, for Assessment Year 2017-18. The source preview indicates that the appellant had informed the CIT of certain facts (the text is truncated), and the grounds raise issues in law and on facts concerning the revision; the source preview does not disclose the tribunal's substantive ruling on the sections cited.

8. Memana Agencies, Cherthala vs The Commercial Tax Officer

Bench: Kerala High Court
Date: 6 April 2022
Sections engaged: 11(3), 25
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP(C) No. 5467 of 2017) was filed before the Kerala High Court by Memana Agencies, Cherthala, represented by its proprietor, against the Commercial Tax Officer and connected respondents in the Department of Commercial Taxes. The source preview lists associated O.T. Rev. Nos. 124/2013, 111/2015, 139/2015, 205/2015, 51/2017, and 173/2017, as well as WP(C) Nos. 41172/2017 and 35915/2018; the source preview does not disclose the court's substantive findings or the basis on which the cited provisions were engaged.

9. State Of Tamil Nadu vs M.S. Viswanathan

Bench: Supreme Court of India
Date: 20 September 2021
Sections engaged: 10(1), 11(1), 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter came before the Supreme Court of India as Civil Appeal No. 5881 of 2010 (along with Civil Appeal No. 5885 of 2010), filed by the State of Tamil Nadu and officials of the Urban Land Ceiling Department, challenging an order of the Division Bench of the Madras High Court dismissing an intra-court appeal and a subsequent order refusing to condone delay in seeking review. Per the source preview, the underlying proceedings concerned the Tamil Nadu Urban Land (Ceiling and Regulation) Act, 1978, and involved a landholder who had filed a return under Section 6(1) of that Act on 20 September 1976 and applied for exemption under Section 19 of that Act on 26 February of the relevant year; the source preview does not disclose the Supreme Court's ultimate ruling on the sections cited.

10. K.V.Prasadan vs K.Thahira

Bench: Kerala High Court
Date: 7 September 2021
Sections engaged: 11(2)(b), 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter came before the Kerala High Court as RCREV. No. 200 of 2020, arising from RCP 61/2012 of the Munsif Court, Kuthuparamba, Kannur, and was finally heard on 22 July 2021 with the order delivered on 7 September 2021. The proceedings are identified as a Rent Control Revision; the source preview does not disclose the court's substantive findings or the basis on which the cited provisions were engaged in this context.

11. Rajashree Polyfil (A Division Of vs State Of Gujarat

Bench: Gujarat High Court
Date: 4 March 2020
Sections engaged: 11(3), 41
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter came before the Gujarat High Court at Ahmedabad as R/Special Civil Application No. 18715 of 2018 along with R/Special Civil Application No. 14975 of 2019, filed by Rajashree Polyfil (a division of Century Enka Ltd.) and one other petitioner against the State of Gujarat. The source preview indicates the dispute concerned state sales made against C form declarations; the source preview does not disclose the court's substantive ruling on the sections cited.

12. State Of Punjab & Ors vs M/S Shreyans Indus.Ltd.Etc

Bench: Supreme Court of India
Date: 4 March 2016
Sections engaged: 11(10), 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter came before the Supreme Court of India as Civil Appeal Nos. 2506–2521 of 2016 (arising out of multiple SLPs filed between 2009 and 2015), filed by the State of Punjab challenging judgments of the High Court of Punjab and Haryana. Per the source preview, all the appeals involved an identical issue pertaining to the interpretation to be accorded to sub-section (10) of Section 11 of the Punjab General Sales Tax Act, 1948, and were heard together and disposed of by a common judgment with SLP (C) Nos. 21712–21717 of 2009 taken as the lead case; the source preview does not disclose the Supreme Court's substantive ruling.

Patterns across these 12 rulings

Multi-statute citation of the "11(3)" label. Across the twelve rulings, the provision cited as "11(3)" does not uniformly refer to Section 11(3) of the Income Tax Act, 1961. Several cases — including those from the Madhya Pradesh High Court, Gujarat High Court, Kerala High Court, and Supreme Court — appear to engage Section 11(3) of other enactments (the Arbitration and Conciliation Act, 1996; state sales tax statutes; the Punjab General Sales Tax Act, 1948; rent control or civil procedure contexts). Researchers must verify the specific statute before applying any ruling to an income-tax matter.
Concentration of income-tax specific rulings at the ITAT level. Of the twelve cases, the clearest income-tax exemption context under the Income Tax Act, 1961 is found in the ITAT rulings (cases 4, 5, 6, and 7), all of which involve charitable or religious trusts or educational institutions seeking exemption, with the revenue side disputing the availability of accumulated income benefits.
Absence of disclosed operative outcomes. Across all twelve cases, the source data does not disclose a definitive outcome direction. Researchers relying on this index for outcome-level analysis must access the full authenticated judgments, as the available previews are truncated at the procedural or introductory stage.
Revision and reassessment as a recurring procedural trigger at the ITAT. Among the ITAT rulings, proceedings appear to have been triggered by CIT revision orders, CIT(A) confirmation of CPC adjustments, and similar second-order proceedings rather than original assessments — suggesting that section 11(3) issues in the income-tax context frequently surface at the appellate or revisionary stage rather than at the first assessment.
Geographic spread across multiple forums. The twelve rulings originate from the Supreme Court (2 cases), Bombay High Court (2 cases), Kerala High Court (2 cases), Gujarat High Court (1 case), Madhya Pradesh High Court (1 case), ITAT Pune (1 case), ITAT Rajkot (1 case), ITAT Ahmedabad (1 case), and ITAT Mumbai (1 case), reflecting that the "11(3)" citation appears across a wide range of forums and statutory regimes — a further reason for careful verification of statutory context before use.

How to use this compilation

This index is designed as a first-pass discovery tool. Each entry identifies the forum, bench, date, sections engaged, and the available procedural ground drawn from the source preview. Because all twelve source previews are truncated — many ending at the introductory paragraphs of the judgment — this compilation does not and cannot substitute for reading the full authenticated text of each ruling. Researchers should retrieve the complete judgment from indiankanoon.org, the relevant court's official portal, or a subscribed legal database before drawing any conclusion about what the court or tribunal actually held.

Before relying on any ruling listed here, researchers should additionally check whether the decision has been stayed, reversed, modified, or distinguished by a subsequent order; whether an appeal to a higher forum is pending or has been decided; and whether the CBDT has issued any circular, instruction, or clarification that bears on the statutory provision in question. Section 11(3) of the Income Tax Act, 1961 has a specific technical operation within the trust exemption framework, and its interaction with other sub-sections of Section 11 and with Section 13 can affect how a particular ruling applies to a different fact pattern.

Finally, researchers should note that several rulings in this compilation engage a provision labelled "11(3)" within a non-income-tax statutory framework. The presence of that label in the sections-cited field does not confirm that the Income Tax Act, 1961 was the governing statute. Cross-referencing the court's own identification of the Act under consideration — available in the full judgment — is essential before classifying any of these rulings as income-tax precedent.

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(3) Case Law: 12 Rulings Across Courts and Tribunals (2016–2026)