Tax Exemption Under Section 10(23C)

Most
NGOs in India claim exemption u/s 11 by registering u/s 12AA of the Income tax
Act 1961. However, a few also claim tax exemption under the relatively less
known Section 10(23C). Three questions are frequently asked:
Q. 1. What is the benefit of registration u/s 10(23C)
over registration u/s 12AA?
A. 1. Earlier there were several benefits that
organisations registered u/s 10(23C)(iv) & (v) enjoyed, including no
requirement to file tax returns, no requirement to spend 85% of the income on
objects, etc. However, with various amendments over the last 16 years,
compliance for an organization registered u/s 10(23C) (iv) & (v) is now
more or less on par with one resisted u/s 12AA
Q. 2. Can every NGO register u/s 10(23C) (iv) & (v)?
A. 2. Broadly speaking exemption u/s 10(23C) (iv)
& (v) can be availed by universities, educational institutions, hospitals
and medical institutions.
Q. 3) Can an NGO be registered under both?
A. 3. Yes. An institution registered under
10(23C) (iv) & (v) may also be registered u/s 12AA and the vice versa.
Application Process
Application
in the prescribed form No 56 should be submitted to the Director General
(Income tax – Exemptions), through the commissioner of income tax, having
jurisdiction over the trust or institution.
Sections
11 & 10(23C) are mutually exclusive
Exemption u/s 10(23C) (iv) or (v) can
be obtained by a charitable institution, in addition to the exemption granted
u/s 11 which also deals generally with charitable or religious activities.
Notably
Section 10(23C) does not prescribe any stipulation which makes registration u/s
12AA a mandatory condition. The provisions of section 11 and 10(23C) are two
parallel regimes and operate independently in their respective realms.
Relevant Case laws
·      
In Commissioner Of Income tax
Vs. Mahasabha Gurukul Vidyapeeth Haryana (2010) 326 ITR 25 (Pun), it was held
that Exemption u/s 11 was allowable to the assessee Society running an
educational institution which was registered u/s 12A, once it is held that all
requisite conditions for exemption u/s 11 have been met, even if conditions u/s 10(23C)(vi) have not been complied with, there
will be no bar to seek exemption u/s  11.
Conversely, while claiming the exemption u/s 10(23) (vi), it is not
required to fulfill the conditions mentioned u/s 11 as also exemption u/s
10(23)(vi). Exemption u/s 10(23)(vi) can
be claimed by the assessee without applying for registration us 12A.
·      
In the case of Commissioner of
Income tax Vs. Jeevan Deep Charitable Trust (2014) 361 ITR 0143 (All) the
assessee was registered u/s. 12A as being a charitable institution. However,
its claim for exemption u/s. 10(23C)(vi) was rejected on the ground that the
institution was not solely established for the educational purposes. Relying on
the same, assessee’s registration u/s. 12A was cancelled by CIT. The High Court held that exemption u/s.
10(23C)(vi) can be claimed by an assessee without applying for registration
u/s. 12A as it is not required to fulfill the conditions mentioned u/s. 11 and
hence the registration u/s 12A was restored.
To
know more about CAP’s legal advisory write to –
connect@capindia.in
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