Roman Catholic Church of the Most Sacred Heart vs. Commissioner of Income Tax (Exemptions)

Parties Involved

Facts Summary

The assessee, a charitable trust operating since 1971, registered under the Maharashtra Public Trusts Act, 1950, and under Section 12AB of the Income Tax Act, filed an application for renewal of registration. The Commissioner of Income Tax (Exemptions) rejected the application on the ground that the assessee failed to furnish the instrument of trust/Memorandum of Association (MoA). The assessee appealed against this decision, arguing that it is governed by Canon Law and does not require a formal written trust deed. The assessee also submitted that it has been consistently registered and granted exemptions for several decades.…

Legal Issues

• 1. Whether the Commissioner of Income Tax (Exemptions) was justified in rejecting the application for renewal of registration under Section 12AB solely on the ground that the assessee failed to furnish the instrument of trust/MoA.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• ITA 5644/MUM/2026

  Mumbai bench

• Church of Our Lady of Immaculata Conception, Church of Our Lady of Assumption, Church of Our Lady of Perpetual Succor v. CIT (Exemption), Mumbai

  Mumbai bench

• St. Judes Church Vs. CIT(Exemptions)

  Mumbai bench

• Nithi Educational Trust Vs. The Commissioner of Income Tax (Exemptions), Bangalore

  Bangalore benchAY N.A.Allowed

• Rotary Club of Mumbai Soho Charitable Trust Vs. CIT(Exemptions), Mumbai

  Mumbai Bench benchAY NAAllowed

• Sunanda Birla Foundation vs. Commissioner of Income Tax (Exemptions)

  Mumbai bench