The legal case between Artemis Education & Research Foundation and the Commissioner of Income Tax (Exemptions), Chandigarh, involves the appeal against the denial of registration under Section 12AA and approval under Section 80G of the Income Tax Act. The case, numbered ITA No. 8/DEL/2021, was presided over by Shri R.K. Panda and Shri Kuldip Singh at the Delhi Bench ‘A’ of the Income Tax Appellate Tribunal.
The appellant, Artemis Education & Research Foundation, primarily engages in medical research and education through various charitable activities. The denial by the CIT (Exemptions) was based on concerns that the organization’s activities, though claimed as charitable, might serve commercial interests or fail to sufficiently impact the public at large. Notably, the CIT (E) questioned the charitable nature of medical research and the organization’s compliance with statutory provisions for non-profit activities.
The Tribunal’s decision on November 24, 2021, emphasized the broad interpretation of ‘charitable purposes’ under the Income Tax Act, which includes advancement of any object of general public utility. It underscored that not all activities with potential commercial outcomes should negate the charitable nature if the predominant intent aligns with public welfare.
The decision reinstated the registration under Section 12AA and approved Section 80G, recognizing the foundation’s right to fiscal benefits attributed to its charitable status. This case sets a precedent for how charitable organizations engaging in medical research and education can qualify for tax exemptions and deductions under Indian tax laws.
Order pronounced on November 24, 2021, clarified the application of charitable status provisions, influencing how similar cases might be adjudicated in the future.
Manage the increasing number of hearings effortlessly by leveraging the legal AI revolution We are India's Leading revolutionary AI-powered legal platform where you can get enough insights into top cases and judgements.
Research Platform