This compilation indexes twelve Indian court and tribunal orders—spanning the Income Tax Appellate Tribunal, Delhi High Court, the Supreme Court of India, and the Customs, Excise & Service Tax Appellate Tribunal—in which Section 12A of one or more Indian statutes was cited as a relevant provision. The rulings cover the period April 2022 to May 2026. Because Section 12A appears across multiple legislative frameworks (the Income Tax Act, 1961; the Insolvency and Bankruptcy Code, 2016; the Foreign Contribution (Regulation) Act, 2010; the Central Excise Act/Finance Act transitional provisions; and others), researchers will note that not all cases here concern income-tax exemption registration directly. Each entry identifies the statute implicated by the text preview and the sections on record. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers conducting preliminary citation mapping.

Research index only. This page is a structured case-law reference compiled from publicly available judgments. Nothing on this page constitutes legal or tax advice. Readers must consult qualified professionals and verify each ruling against the full, official judgment text before relying on it.

The statutory framework in one paragraph

Section 12A of the Income Tax Act, 1961 prescribes the conditions precedent for a trust or institution to claim exemption under Sections 11 and 12 of that Act; in its current form (as amended and supplemented by Section 12AB), it requires the trust or institution to make an application for registration in the prescribed form and manner before the Principal Commissioner or Commissioner of Income Tax, and registration so granted is a sine qua non for the availability of the exemption. Separately, the label "Section 12A" also appears in other Indian statutes—including the Central Excise Act, 1944, the Finance Act, 1994, the Insolvency and Bankruptcy Code, 2016, and the Foreign Contribution (Regulation) Act, 2010—where it carries distinct meanings specific to those enactments. Researchers must therefore identify the governing statute in each ruling before drawing substantive conclusions about the provision's operation.

The 12 rulings

1. M/S Cri Limited vs Pran Nath Mehta & Ors

Bench: Delhi High Court
Date: 18 May 2026
Sections engaged: 12A, 13, 27, 50, 6A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (RFA (COMM) 486/2025) was preferred by the original defendant before the Delhi High Court under Section 13(1A) of the Commercial Courts Act, 2015 read with Order XLI of the Code of Civil Procedure, 1908; the matter was reserved on 28 October 2025 and pronounced on 18 May 2026. The source preview is procedural in nature and does not set out the substantive disposition; the full judgment would need to be consulted to ascertain the ground on which the sections listed were engaged in this commercial appellate context.

2. Shushrusha Gitizens Co Operative vs ACIT (Exemption) Circle -2, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 2 April 2026
Sections engaged: 11, 12A, 13(1)(c), 13(3), 13(3)(b), 142(1), 144A, 2(15), 250, 80P, 9(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals before the ITAT Mumbai "SMC" Bench covered ITA No. 21/Mum/2026 (Assessment Year: 2015-16) and ITA No. 6785/Mum/2025 (Assessment Year: 2016-17), filed by Shushrusha Gitizens Co Operative Hospital Limited (PAN/GIR No. AAATS0257K) against the ACIT (Exemption) Circle-2, Mumbai. The source preview indicates the matter involved computation of income with reference to exemption claimed, depreciation adjustments, and disallowances across both assessment years; the substantive outcome is not specified in the available source extract.

3. Chikmagalur Golf Club vs Mysore

Bench: Custom, Excise & Service Tax Tribunal
Date: 10 March 2026
Sections engaged: 12A, 65(105), 78
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 145 of 2012) arose from an Order-in-Original dated 11.10.2011 passed by the Commissioner of Central Excise, Customs and Service Tax, Mysore, wherein a service tax demand of Rs. 52,85,307/- was raised against the appellant for the period 16.06.2005 to 31.03.2009 under the category of 'Club or Association Service', subsequently reduced on adjudication to Rs. 50,98,330/- with interest and equivalent penalty. The appellant submitted before the Tribunal that it is a charitable trust registered on 03.11.2000 with the objective of promoting golf and other games and tourism, and that it is registered as a charitable trust with the Income Tax Department; the substantive outcome is not specified in the available source extract.

4. M/S Saraswati Wire And Cable Industries vs Mohammad Moinuddin Khan

Bench: Supreme Court of India
Date: 10 December 2025
Sections engaged: 12A, 61
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (Civil Appeal No. 12261 of 2024, citation 2025 INSC 1410, Non-reportable) concerned the initiation of a corporate insolvency resolution process under the Insolvency and Bankruptcy Code, 2016 by an operational creditor. The NCLAT had set aside the NCLT's admission order on the ground that there was a pre-existing dispute between the parties as to the firm's debt prior to institution of the application, and the firm appealed to the Supreme Court; the source preview does not disclose the Supreme Court's final disposition.

5. Ram Niwas Modi Charitable vs CIT-Exemption, Jaipur, Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 20 November 2025
Sections engaged: 80G, 12A
Outcome: Taxpayer succeeded
Procedural / substantive ground: The two appeals (ITA No. 118 & 779/JPR/2025) were filed by Ram Niwas Modi Charitable Society (PAN/GIR No. AAATR8150J) against orders of the CIT (Exemptions), Jaipur dated 31.12.2024 and 03.04.2025, both concerning the rejection of the assessee's application for registration under Section 80G of the Income Tax Act. The assessee challenged the impugned order dated 31.12.2024 as non-est, bad in law, and passed without jurisdiction; the outcome classification recorded in the source is that the taxpayer succeeded, though the full reasoning in the judgment should be verified against the complete order.

6. Bilcare Ltd vs Commisioner Central Excise And Service

Bench: Custom, Excise & Service Tax Tribunal
Date: 25 August 2025
Sections engaged: 11B, 11B(2), 11B(2)(d), 12A, 142(2), 142(9)(b), 174
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Excise Appeal No. 85979 of 2022) arose from an Order-in-Appeal dated 31.12.2021 passed by the Commissioner of Central Tax (Appeals-I), Pune. The source preview indicates the dispute concerned a refund application dated 18.08.2020 for Rs. 19,67,766/- filed by the appellants on the basis of an earlier Tribunal final order dated 07.10.2019 and an order of original authority dated 01.08.2019; the refund claim was rejected by the original authority vide order dated 28.03.2021 on grounds of time bar and inadmissibility of a portion of the amount. The substantive outcome of the CESTAT appeal is not specified in the available source extract.

7. Rankuno Interactive Technologies Pvt vs Pune-Iii

Bench: Custom, Excise & Service Tax Tribunal
Date: 17 February 2025
Sections engaged: 11B, 11B(2), 12A, 142(2), 142(3), 142(9)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Service Tax Appeal No. 85387 of 2022) arose from an Order-in-Appeal dated 30.09.2019 passed by the Commissioner (Appeals-II), CGST, Customs & Central Excise, Pune. Per the source preview, the appellants had paid Rs. 12,86,186/- as service tax on Reverse Charge Mechanism basis against services availed from foreign service providers under the category of Online Information Database Access and Retrieval (OIDAR) services, and had filed a refund claim in Form-R for that amount on 10.01.2019; the substantive outcome of the CESTAT appeal is not specified in the available source extract.

8. Lupin Limited vs The Assistant Commissioner GST & Cex

Bench: Custom, Excise & Service Tax Tribunal
Date: 9 September 2024
Sections engaged: 11B, 11B(2), 12A, 140(1), 142(3), 142(9), 142(9)(b), 174
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Excise Appeal No. 85756 of 2020) arose from an Order-in-Appeal dated 13.01.2020 passed by the Commissioner (Appeals), GST & Central Excise, Nashik. Per the source preview, the appellants had filed a revised ER-1 for the month of June 2017 on 31.07.2017 indicating admissible CENVAT credit of Central Excise duty and Service Tax for an additional amount of Rs. 30,52,536/- on inputs, capital goods and input services not claimed in the earlier pre-revised return; the substantive outcome of the CESTAT appeal is not specified in the available source extract.

9. Shri. Shridevi Charitable Trust vs The Principal Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 26 July 2024
Sections engaged: 12A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 709/Bang/2023, Assessment Year: 2023-24) was filed by Shri Shridevi Charitable Trust, Tumkur (PAN No. AADTS8255N) against an order of the PCIT (Central), Bangalore passed under Section 12AB(4)(ii) of the Income Tax Act, 1961 dated 28.7.2023, cancelling the assessee's registration on the ground that the appellant's case falls under a specified violation explained under the Explanation to Section 12AB. The assessee challenged the cancellation as erroneous in law and prejudicial to its interests; the substantive outcome is not specified in the available source extract.

10. M/S Arif Azim Co. Ltd vs M/S Aptech Ltd

Bench: Supreme Court of India
Date: 1 March 2024
Sections engaged: 12A
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (Arbitration Petition No. 29 of 2023, citation 2024 INSC 155, Reportable) was filed before the Supreme Court of India in its civil original jurisdiction. The source preview indicates the dispute involved a franchise agreement between the parties, addressing matters of appointment, renewal, and the status of the agreement; the source preview is procedural and contractual in nature, and does not disclose the substantive ground on which the listed section was engaged or the court's final disposition.

11. M/S Platinum Theatre vs Competent Authority Smugglers And

Bench: Supreme Court of India
Date: 22 March 2023
Sections engaged: 12A, 2(1), 2(2), 2(2)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Civil Appeal No. 4369 of 2009, Reportable) was directed against a judgment dated 19 April 2007 of the High Court of Karnataka upholding an order of the competent authority under the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 dated 31 December 1997. Per the source preview, the appellant is described as a registered partnership firm and the proceedings concerned the forfeiture of property in connection with one of its partners, N.A. Yusuf, who had been ordered to be detained under COFEPOSA; the substantive outcome of the Supreme Court appeal is not specified in the available source extract.

12. Noel Harper vs Union Of India

Bench: Supreme Court of India
Date: 8 April 2022
Sections engaged: 12, 12A, 16, 17(1), 2(1)(e)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter (Writ Petition (Civil) No. 566 of 2021, along with connected Writ Petition (Civil) Nos. 634 and 751 of 2021, Reportable) was filed under Article 32 of the Constitution of India primarily assailing the constitutional validity of amendments to the Foreign Contribution (Regulation) Act, 2010 introduced by the Foreign Contribution (Regulation) Amendment Act, 2020, which came into effect on 29.9.2020, including the amended provisions in Sections 7, 12(1A), 12A, and 17(1) of that Act. The petitioners challenged those amendments as manifestly arbitrary, unreasonable, and as impinging upon the fundamental rights guaranteed under Articles 14, 19, and 21 of the Constitution; the substantive outcome is not specified in the available source extract.

Patterns across these 12 rulings

Section 12A as a cross-statute citation marker. Across these twelve rulings, "Section 12A" appears in at least five distinct legislative frameworks — the Income Tax Act 1961 (charitable trust registration/exemption), the Insolvency and Bankruptcy Code 2016, the Foreign Contribution (Regulation) Act 2010, the Central Excise Act/Finance Act transitional provisions, and other civil/commercial enactments. Researchers must identify the governing statute before treating any two rulings as analogous on a "Section 12A" basis.
Refund and credit disputes dominate the indirect-tax docket. Cases 6, 7, and 8 (Bilcare Ltd, Rankuno Interactive Technologies, and Lupin Limited) all involve CESTAT Mumbai and share a common factual template: pre-GST CENVAT credit or service tax amounts sought as refunds under transitional provisions, with rejections at original authority level being the trigger for appeal.
Charitable trust registration and cancellation as a recurring income-tax theme. Among the income-tax cases, Cases 2, 5, and 9 all engage the registration or exemption framework for charitable trusts and institutions under the Income Tax Act, with disputes before the ITAT at Mumbai, Jaipur, and Bangalore respectively — reflecting the ongoing litigation wave following the mandatory re-registration requirements introduced under the amended provisions.
Outcome data is sparse. Of the twelve rulings indexed, only one (Case 5, Ram Niwas Modi Charitable) carries a recorded outcome direction ("Taxpayer succeeded"). The remaining eleven are recorded as "Outcome not specified in source." Researchers should treat this compilation as an entry point for locating full judgments rather than as a dispositive outcome summary.
Multi-forum spread. The twelve rulings span multiple distinct forums — ITAT Mumbai, ITAT Jaipur, ITAT Bangalore, Delhi High Court, Supreme Court of India, and CESTAT Mumbai — illustrating that Section 12A (across statutes) is litigated at every level of India's tax and civil appellate hierarchy simultaneously.

How to use this compilation

This index is designed as a starting point for citation mapping, not as a substitute for reading the full judgment. Each entry provides the forum, date, sections engaged, and — where the source data supports it — a brief procedural note. Before relying on any ruling in a legal submission, memorandum, or compliance analysis, readers should retrieve the complete order from the relevant official portal (indiankanoon.org, the ITAT e-filing portal, the Supreme Court of India website, or the CESTAT portal as appropriate), verify that no appeal, stay, or reversal has supervened, and check whether a Special Leave Petition or Letters Patent Appeal has been filed against the order.

Researchers should also cross-check each ruling against contemporaneous CBDT circulars, instructions, and press releases, particularly for matters touching charitable trust registration (where CBDT has issued multiple administrative clarifications following the Section 12AB re-registration drive), and against any CBIC instructions relevant to the transitional CENVAT/GST credit disputes in the CESTAT cases. Judicial outcomes and administrative guidance can move in opposite directions on the same legal question, and the full picture requires both to be assessed together.

Finally, note that the "Sections engaged" field in each entry reflects the sections cited on the face of the order as extracted from the source corpus — it is not a curated list of "sections actually decided upon." Some sections listed may have been cited only in passing, in a table of authorities, or in a quoted statutory text. The substantive holding on each section can only be determined from the full judgment text.

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 12A Across Indian Courts: 12 Rulings Indexed (2022–2026)