In the case D.L. Shah Trust v. Deputy CIT, the ITAT ruled that transferring accumulated funds to another charitable institution incurs tax consequences under section 11(3)(d). The trust argued that payments to organizations like QCI and TERI represented direct applications of accumulated income. However, the Tribunal clarified that the Income-tax Act differentiates between current and accumulated income, emphasizing that the lack of exception for implementing agencies means such transfers are ta

In ASCI v. CIT, the Mumbai ITAT ruled that foreign remittances for software subscriptions and international memberships used to support domestic consumer-awareness and regulatory tasks do not violate Section 11(1)(c). Because the ultimate benefit and utilization of these expenses remain within India, they cannot be classified as income applied abroad. Additionally, the Tribunal ordered tax authorities to re-evaluate registration delays using historical Section 80G approvals.

The ITAT Chandigarh ruled that pre-school and kindergarten activities constitute “education” under Section 2(15) of the Income-tax Act, recognizing Early Childhood Care and Education (ECCE) as part of the formal education system. It held that registration under Section 12AB cannot be denied based on alleged Section 13 violations, as such issues must be examined during assessment proceedings. The Tribunal directed the tax authorities to grant charitable registration to the assessee society.