Susila Educational Trust faced a denial of exemption for Assessment Year 2018-19 after filing its return under Section 139(4) later than the original statutory deadline. The Assessing Officer examined the trust’s records and observed that income of ₹79,92,658 had been claimed as exempt under Section 11 of the Income-tax Act, 1961. Although the trust had declared nil income after claiming charitable exemption and had furnished its audit report in Form 10B, the Assessing Officer denied the exemption solely because the return was not furnished within the time limit.
The trust appealed this denial to the Income Tax Appellate Tribunal (ITAT) Chennai Bench. The dispute centered on whether the late filing of the Income Tax Return automatically resulted in the loss of the exemption under Section 11. The trust had previously met the substantive requirements by providing the necessary audit details, making the procedural delay the primary point of contention in the litigation.
On 2026-10-16, the ITAT Chennai allowed the appeal of Susila Educational Trust. The Tribunal directed the Assessing Officer to grant the exemption of ₹79,92,658 under Section 11 for the assessment year in question. This decision was based on the interpretation of Section 12A(1)(ba) and relevant circulars, which addressed the interaction between the registration status of the trust and the filing timelines. By allowing the appeal, the Tribunal effectively validated the trust's claim for the exemption despite the procedural lapse in the original return filing.
On 2026-10-16, the ITAT Chennai allowed the appeal of Susila Educational Trust.