This compilation indexes twelve tribunal and High Court decisions—pronounced between January 2026 and July 2026—in which Section 13(1)(c) of the Income-tax Act, 1961 was a cited or central provision. The cases span ITAT benches at Bangalore, Chandigarh, Delhi, Mumbai, Lucknow, Surat, and Ranchi, as well as the Karnataka High Court and the Delhi High Court. It is intended as a structured research reference for in-house tax teams, Big-4 associates, and law firm researchers who need a consolidated view of recent adjudication touching this provision.

Disclaimer: This page is a research index only. Nothing here constitutes legal or tax advice. Readers must verify every ruling against the full, authenticated judgment and check for subsequent stays, reversals, or CBDT instructions before drawing any conclusions.

The statutory framework in one paragraph

Section 13(1)(c) of the Income-tax Act, 1961 withdraws the exemption otherwise available under Sections 11 and 12 where any part of the income or property of the trust or institution is, or continues to be, applied—directly or indirectly—for the benefit of any person referred to in Section 13(3), which includes the author, founder, trustee, manager, or any relative of such persons, as well as any concern in which such persons have a substantial interest. The provision is a safeguard against diversion of charitable funds for private benefit, and its invocation by an Assessing Officer triggers denial of the full exemption claim for the relevant assessment year, not merely a proportionate disallowance.

The 12 rulings

1. Shanthi Vidya Mandir Education Society vs Exemptions Ward 3,Blr, Bengaluru

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 30 July 2026
Sections engaged: 11(1), 12A, 13(1)(c), 13(3), 143(3), 144B, 246A, 250(4), 250(6), 251(1)(a), 251(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee-society (ITA 2905/BANG/2025) for Assessment Year 2022-23 against the appellate order of the CIT(A). Per the source preview, the assessee's grounds included a challenge that the CIT(A) had disposed of the matter ex parte without granting a proper, effective, and meaningful opportunity of hearing, thereby allegedly violating the mandate of Section 250(6) and the principles of natural justice. It was further alleged that the CIT(A) failed to pass a reasoned and speaking appellate order.

2. A.D. Educational Society,C/O Akul vs DCIT/ACIT Exemptions Circle - 2

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 27 July 2026
Sections engaged: 12A, 13(1)(c), 13(2), 13(3), 143(1), 147
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 1190/Chd/2025) was filed by the assessee-society against the order of the CIT(A), NFAC, Delhi dated 22/07/2025 for Assessment Year 2016-17. Per the source preview, the matter was heard through hybrid mode before the Chandigarh Bench. The substantive disposition is not captured in the available source preview beyond identification of the parties and the assessment year in dispute.

3. DCIT, Exemption Circle, Ghaziabad vs Rishab Kumar Lohia Memorial Trust

Bench: Income Tax Appellate Tribunal - Delhi
Date: 15 July 2026
Sections engaged: 11, 13(1)(c), 13(2), 13(3), 13(3)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1768/DEL/2026) for Assessment Year 2023-24 arose from an order dated 17.12.2025 passed under Section 250 by the CIT(A)-NFAC, Delhi. Per the source preview, during the year under consideration the assessee-trust had received Rs. 2.28 crores as CSR funds from M/s Lohia Corp. Limited, and thereafter Rs. 33 lakhs was returned/refunded by the assessee to M/s Lohia Corp, ostensibly on the ground that the amount was required to be spent through another channel; these facts formed the factual matrix before the Tribunal in the context of the sections engaged.

4. B H Narayanappa vs The State Of Karnataka

Bench: Karnataka High Court
Date: 7 July 2026
Sections engaged: 13(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter was heard as Writ Petition No. 24242 of 2017 (GM-RES) along with Writ Petition No. 16306 of 2017 (GM-RES) before the Karnataka High Court at Bengaluru, reserved on 25.06.2026 and pronounced on 07.07.2026. Per the source preview, the petitioner was the Commissioner of Davanagere Mahanagara Palike; the respondents included the State of Karnataka (Home Department), Karnataka Lokayuktha, and Anti-Corruption Bureau officers. The writ petitions were filed under Articles 226 and 227 of the Constitution; the substantive findings are not captured in the available source preview.

5. Shri Krishna Hare Educational vs Income Tax Officer, Ward Exemp 2(2)

Bench: Income Tax Appellate Tribunal - Delhi
Date: 2 July 2026
Sections engaged: 11, 13(1)(c), 13(3), 13(3)(e)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 5003/Del/2025) was filed by the assessee-trust against the order of the CIT(A) dated 26.06.2025, which itself arose from an assessment order dated 27.12.2017 for Assessment Year 2015-16. Per the source preview, the assessee is a charitable trust registered under Section 12A of the Income-tax Act vide order dated 07/01/2010, and the original assessment was framed under the provisions of the Act for A.Y. 2015-16; the precise substantive findings of the Tribunal are not captured in the available source preview.

6. Bantval Sulochana Madhava Shenoi vs CIT(Exemptions), Bengaluru

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 29 June 2026
Sections engaged: 11(1), 13(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1324/Bang/2026) was filed by Bantval Sulochana Madhava Shenoi Trust for Assessment Year 2018-19 against the appellate order dated 28 March 2026 of the CIT(A)-NFAC, which had dismissed the assessee's challenge to the assessment order passed under Section 143(3) read with Section 144B dated 31/03/2021. Per the source preview, the appellant is a charitable trust registered under Section 12A that runs Kamakshi Hospital, providing healthcare services mainly to poor and middle-class patients; the CIT(A) had dismissed the assessee's appeal on the merits before the ITAT took up the matter.

7. Ms Pernod Ricard India Pvt Ltd Through vs The Excise Department Delhi Government

Bench: Delhi High Court
Date: 29 May 2026
Sections engaged: 13(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter was filed as W.P.(C) 3806/2026 before the Delhi High Court, reserved on 20.05.2026 and pronounced on 29.05.2026. Per the source preview, the petitioner is M/s Pernod Ricard India Pvt. Ltd. and the respondents are the Excise Department and Excise Commissioner, Govt. of NCT of Delhi; the petition was filed under Article 226. The substantive findings of the Court are not captured in the available source preview, and only Section 13(1)(c) appears as a cited provision in the source data for this matter.

8. Aditya Birla Foundation,Mumbai vs Income Tax Officer (Exemption)-1(1)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 28 April 2026
Sections engaged: 13(1)(c), 13(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter involved cross-appeals across ITA Nos. 6000, 6001 and 7607/MUM/2025 (Assessment Years 2013-14, 2014-15, and 2015-16) filed by the Revenue, and ITA No. 7994/MUM/2025 (Assessment Year 2015-16) filed by the Foundation. Per the source preview, one of the key issues framed by the Tribunal was the allowance of exemption under Section 11 by the CIT(A) on the ground that there was no violation of Section 13(1)(c) read with Section 13(3) of the Act; this framing indicates the Revenue had challenged the CIT(A)'s finding that no benefit to specified persons had occurred.

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

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 2 April 2026
Sections engaged: 11, 13(1)(c), 80P
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals were consolidated: ITA No. 21/Mum/2026 (Assessment Year 2015-16) and ITA No. 6785/Mum/2025 (Assessment Year 2016-17). Per the source preview, the assessee is Shushrusha Gitizens Co Operative Hospital Limited (PAN: AAATS0257K); the tabulated data in the preview records assessment orders passed under Section 143(3) for both years with various additions including depreciation, disallowances, and a "Director's Concession" item of Rs. 1,56,692/- for A.Y. 2015-16 and Rs. 5,29,176/- for A.Y. 2016-17, forming the factual background against which the exemption and the cited sections were considered.

10. Hind Charitable Trust,Lucknow vs PCIT(Central), Lucknow

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 27 February 2026
Sections engaged: 12A, 13(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 26/LKW/2021) was filed by the Trust against the PCIT(Central), Lucknow. Per the source preview, the Revenue's case involved allegations of inflated in-patient department (IPD) receipts characterised as money-laundering tactics; however, the Assessing Officer, having examined the receipts date-wise from seized hard-disk data, found the receipts to be genuine and matching actual bed/OT charges, and accordingly no adverse view was taken on this ground. The corresponding expenditure was also accepted, and the financial integrity of the Trust's accounts was restored per the preview; the registration of the Trust had been cancelled in the original assessment on the premise of non-genuine activity.

11. Abhyuththan Gram Vikas Mandal,Surat vs CIT Exemption, Ahmedabad

Bench: Income Tax Appellate Tribunal - Surat
Date: 19 February 2026
Sections engaged: 11, 13(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: Cross-appeals were filed as I.T.A. No. 838/SRT/2025 (by the assessee) and I.T.A. No. 902/SRT/2025 (by the Revenue), both for Assessment Year 2018-19. Per the source preview, the assessee is a Public Charitable Trust registered with the State Charity Commissioner that undertook irrigation projects awarded by Sardar Sarovar Narmada Nigam Ltd.; during assessment, the Assessing Officer treated the trust's activities as business under Section 2(15), denied exemption, and invoked Section 13(1)(c) alleging interest-free advances had been made.

12. Income Tax Officer, Exemption Ward vs Dukhharan Memorial Charitable Trust

Bench: Income Tax Appellate Tribunal - Ranchi
Date: 14 January 2026
Sections engaged: 13(1)(c), 11
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 261/Ran/2024) was filed by the Revenue against the NFAC, Delhi order dated 20.03.2024 for Assessment Year 2017-18, heard virtually at Kolkata. Per the source preview, the assessee-trust filed its return of income for A.Y. 2017-18 declaring nil income, and the case was subsequently selected for limited scrutiny; the full substantive findings of the Tribunal are not captured in the available source preview beyond this procedural background.

Patterns across these 12 rulings

Consistent co-invocation of Sections 11 and 13(1)(c). Across the majority of ITAT cases in this set—including the Surat, Ranchi, Mumbai (Shushrusha), Delhi (Shri Krishna Hare and Rishab Kumar Lohia), and Lucknow matters—Section 13(1)(c) appears alongside Section 11, reflecting the structural relationship between the two provisions: Revenue invokes Section 13(1)(c) precisely to negate the Section 11 exemption claim.
Charitable trusts running hospitals and educational institutions are disproportionately represented. Five of the twelve cases involve trusts operating hospitals or educational societies (Shanthi Vidya Mandir, Bantval Sulochana/Kamakshi Hospital, Shushrusha Co-operative Hospital, Dukhharan Memorial/Rani Hospital, Hind Charitable Trust/hospital receipts), suggesting Section 13(1)(c) disputes are particularly concentrated in healthcare and education-sector charitable entities.
CIT(A)-NFAC orders form the primary trigger for ITAT appeals. Several cases in this set—Shanthi Vidya Mandir, A.D. Educational Society, Shri Krishna Hare, and Dukhharan Memorial—reflect appeals arising from CIT(A)-NFAC, Delhi orders, consistent with the centralised faceless appellate mechanism now functioning as the first appellate layer for most exemption matters.
Natural-justice and speaking-order challenges accompany the substantive Section 13(1)(c) ground. In at least the Shanthi Vidya Mandir matter, the assessee raised an independent procedural ground that the CIT(A) had failed to provide a meaningful hearing and failed to pass a reasoned order, indicating a pattern where procedural infirmities in first-appellate orders are raised in tandem with the substantive exemption dispute.
Section 13(3) specified-person analysis is a recurring companion issue. Cases involving Section 13(1)(c) consistently also cite Section 13(3), which defines the persons whose benefit triggers the disqualification—visible in the Aditya Birla Foundation, A.D. Educational Society, Shri Krishna Hare, and Rishab Kumar Lohia matters—demonstrating that the factual question of who qualifies as a "specified person" is typically a distinct sub-issue in these proceedings.

How to use this compilation

This compilation is structured as a finding aid, not a digest of settled propositions. Each entry identifies the forum, date, and sections engaged, but because the source previews for several cases are procedural in nature and do not disclose the dispositive paragraph, readers should retrieve the full authenticated text of any ruling of interest from indiankanoon.org or the relevant court/tribunal portal before relying on it for any purpose. The "Outcome not specified in source" designation for all twelve cases means this index does not record which party prevailed; that determination must be made from the complete judgment.

Researchers should additionally verify whether any of these orders have been appealed further—to the High Court (under Section 260A) or to the Supreme Court—or whether any stay of the Tribunal's order is in operation. ITAT orders do not automatically bind coordinate benches, and conflicting views across benches (for example, between Mumbai and Delhi on a particular factual configuration under Section 13(1)(c)) should be cross-checked against the most recent coordinate and jurisdictional High Court precedent.

Finally, CBDT has issued circulars and instructions that bear on the administration of Sections 11–13, including guidance on the scope of charitable purposes under Section 2(15). Those administrative materials are not reproduced here but should be consulted alongside case-law when advising on compliance positions or drafting submissions before an Assessing Officer or appellate authority.

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 13(1)(c) Income Tax: 12 ITAT & HC Rulings on Charitable Trust Exemption Denial (2026)