YOUNG WOMENS CHRISTIAN ASSOCIATION OF INDIA Vs. CIT(EXEMPTION), DELHI

Parties Involved

Facts Summary

The assessee, YOUNG WOMENS CHRISTIAN ASSOCIATION OF INDIA, filed an application electronically on 29.9.2026 in Form 10AB seeking registration u/s. 12A(1)(ac)(iii) of the Income Tax Act, 1961. The applicant was issued a questionnaire on 6.12.2025 with a request to furnish certain details and documents in support of its claim for registration u/s. 12A(1)(ac)(ii) on or before 12.12.2025. In response to the above, the applicant filed its response. After examination of the response of the applicant, the CIT(E) observed that the applicant society is mainly involved in activities for generation of income rather than the charity. Accordingly, the applicant was requested to justify its claim for registration u/s. 12AB as its receipts in all years were substantially from commercial activities. In response to the same, the assessee applicant filed its reply on 13.3.2026 by emphasizing that since all the receipts are utilized for promoting its objectives, they are not commercial even if the receipts are consideration for services provided on quid pro quo basis. The Ld. CIT(E) observed that the applicant has substantial net surplus in absolute terms and hence its markup for commercial transactions is not nominal. Thus, the applicant is not eligible for registration u/s. 12AB as its purpose is not charitable in terms of the proviso to Section 2(15) of the Act, as it works exclusively as a commercial entity. He further observed that the applicant has committed regular specified violation as…

Legal Issues

• 1. Whether the applicant is eligible for registration u/s. 12AB of the Income Tax Act, 1961?
• 2. Whether the applicant is eligible for approval u/s. 80G of the Income Tax Act, 1961?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• AIMAMEDIA FOUNDATION Vs. CIT(Exemption)

  Delhi bench

• Ram Manohar Educational & Samudai Bal Vikas Societ, Basti Vikas Kendra (MCD) Vs. CIT(Exemption), Delhi

  Delhi Benches ‘A’ benchAY N/AAllowed

• Vijayvargia (Vaishya) Rajsevak Parishad (Sanshthan) vs The CIT (Exemption), Jaipur

  Jaipur bench

• Jito Bhavnagar Chapter Foundation vs. CIT(E)

  Ahmedabad bench

• Consortium of Accredited Healthcare Organization vs. CIT (Exemption)

  Delhi bench

• Shri Damodar Gaushala vs The CIT (Exemption), Jaipur

  Jaipur bench