आयकर अपील(cid:547)य अ(cid:876)धकरण,चÖडीगढ़ Ûयायपीठ,चÖडीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘B’ CHANDIGARH BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकर अपील सं. ITA No. 1706/CHD/2025 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Year: 2022-23 Maharaja Jagat Singh The CIT (Exemptions), Medical Relief Society, Vs Chandigarh.

Dera Baba Jaimal Singh, Balsarai, Amritsar.

èथायी लखे ा सं./PAN NO: AAATM1276C अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent Assessee by : Shri Atul Mandhar, Advocate and Ms. Ekakshra Mandhar, Advocate Revenue by : Shri Bharat Bhushan Garg, CIT DR Date of Hearing : 29.01.2026 Date of Pronouncement : 10.02.2026 HYBRID HEARING O R D E R PER RAJPAL YADAV, VP The assessee is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Exemptions) [in short ‘the CIT (E)’] dated 25.11.2025 passed for assessment year 2022-23 vide which ld. CIT (E) has cancelled the registration granted u/s 12A of the Income Tax Act. This order has been passed in Form No. 10(ac) of the Act.

2. The assessee has taken 11 grounds of appeal but its grievance revolves around a single issue, namely, ld. CIT (E) has erred in cancelling the registration granted to the assessee Trust. The pleadings in all other grounds are peripheral arguments in support of the above central point.

3. The ld. counsel for the assessee while impugning the order of ld. CIT (E) took us through the written submissions filed by the Trust and available on page Nos. 1 to 24. He pointed out that assessee Trust was enacted in 1978 under the name and style of Maharaja Jagat Singh Medical Relief Society, Beas. It was registered with Registrar of Firms and Societies, Punjab. It was granted registration u/s 12A of the Income Tax Act as well as 80G. This registration was granted on 18.12.1978 and copy of the registration is available on page No. 104 to 106 of the Paper Book. The assessee Society, later on made changes in its name and the expression ‘Beas’ has been deleted. This change has also been recognized by the Registrar of Firms and Societies on 16.03.2011 and a fresh certificate was given which is available on page 40 of the Paper Book. The ld. counsel for the assessee has apprised us with the objects of the society and we briefly take note of such objectives as under :

OBJECTS OF SOCIETY MEMORANDUM OF ASSOCIATION OF MAHARAJ JAGAT SINGH MEDICAL RELIEF SOCIETY:

I. The name of the Society shall be Maharaj Jagat Singh Medical Relief Society.

II. The Registered Office of the Society shall be situated in the State of Punjab.

III. The objects of the Society to be followed on incorporation shall be:

(1) To acquire, establish, run, give assistance, financial or otherwise, in establishing and/or running hospitals, medical institutions, dispensaries, ambulances and nature cure clinics in India for providing medical relief by the reception and treatment of persons suffering from illness or mental defectiveness or by the reception and treatment of persons during convalescence, or of persons requiring Medical attention or rehabilitation, existing solely for philanthropic purposes and not for purposes of profit.

(2) To establish, run, assist in establishing or running Pathological Laboratories equipped with scientific equipment; to provide assistance, financial or otherwise, to individuals for diagnosis and treatment of their diseases in a specialised hospital through a specialised agency.

(3) To establish /run or assist mobile dispensaries and to organise/assist camps in rural areas for providing medical relief to needy persons irrespective of caste, colour and creed.

(a) To aid and assist the people affected by a grave natural calamity by way of appropriate relief and rehabilitation.

(4) To promote medical research centres for the advancement of medical facilities in India.

(5) To enter into any arrangement with the Government. Central or State, for securing grants-in-aid. benefits and en