ITA Nos. 3147 & 3148/DEL/2026

Parties Involved

Facts Summary

The assessee, Population Services International, was registered under the Societies Registration Act, 1860 and obtained registration under section 12A of the Income Tax Act, 1961. The assessee was involved in activities related to reproductive health, HIV/AIDS prevention, tuberculosis eradication, and maternal and child health. The assessee had received approval under section 80G and section 10(23C)(iv) of the Act. However, the approval under section 10(23C)(iv) was rescinded by the Commissioner of Income-tax (Exemptions) on 16.03.2021. The Assessing Officer issued a reassessment order on 30.05.2022, which was appealed by the assessee. The Commissioner of Income Tax (Appeals) allowed the appeal, and the revenue authority further appealed to the Income Tax Appellate Tribunal.…

Legal Issues

• 1. Whether the assessee is carrying charitable activities as envisaged under Section 2(15) read with Section 10(23C) of the IT Act, 1961.
• 2. Whether the Commissioner of Income Tax (Appeals) erred in allowing the appeal of the assessee.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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