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INCOME TAX APPELLATE TRIBUNAL (CHENNAI BENCH)
PADMAVATHY.S, Accountant Member, Manu Kumar Giri, Judicial Member
Livesurge Medical & Research Trust – Appellant
Versus
Commissioner of Income Tax (Exemption) – Respondent
| Table of Content |
|---|
| 1. trust objects charitable for public medical/educational aid. (Para 2 , 3) |
| 2. cit(e) rejected registration citing mutuality, no public benefit. (Para 4 , 5) |
| 3. non-commencement no bar; consider proposed charitable activities. (Para 6 , 7) |
| 4. appeal allowed; direct grant of registration u/s 12ab. (Para 8) |
आदेश/ORDER
PER PADMAVATHY.S, A.M:
This appeal by the assessee is against the order of the Commissioner of Income Tax (Exemptions), Chennai (in short "CIT(E)") dated 29.09.2025. The issue contended in this appeal pertain to the denial of registration u/s. 12AB of the Income Tax, 1961 (in short "the Act").
2. The assessee is a charitable trust formed vide trust deed dated 15.07.2024. As per the trust deed, the objects of the trust are as listed below:
“1) To set up Out Patient Department, Clinic, Medical facilities to provide health care to public at large at concessional rates/free of cost.
2) Granting of financial assistance to deserving students, educational institutions for granting scholarships, prizes, medals, awards for excellence in studies, sports and scientific research, distribution of books and note books for poor and deserving students.
3) To spread public awaren
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