Chilume Social Service Society v. The Income Tax Officer (Exemptions), Ward-1, Bangalore

1. FACTS OF THE CASE

ITA 121/2025 concerned only Tribunal appeal 250/Bang/2025 for AY 2020-21, part of the common ITAT order dated 28 May 2025. The Additional/JCIT(A)-1, Jaipur had rejected the first appeal on limitation on 13 December 2024.

Source: PDF pp.1–2

2. DISCUSSION BY THE COURT

The explanation for inordinate delay was the trustees’ ill health, without supporting material. The ITAT found no infirmity. The High Court found no perversity and noted that connected ITAs 122 and 123/2025 had been dismissed on 1 August 2025.

Source: PDF p.3, paras 2–4

3. JUDICIAL DECISION

No substantial question of law arose. The appeal was dismissed and pending applications disposed of.

Source: PDF pp.3–4, paras 4–6

4. OUTCOME

Revenue successful on limitation; no determination of the society’s substantive tax claim.

Source: PDF pp.3–4

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Evidence was the missing link

The explanation identified illness but supplied no material showing its effect on filing. A useful condonation record would connect the medical circumstances, the persons responsible for the society’s affairs and the period of default. Mere repetition of an unsupported explanation did not reveal perversity in the appellate refusal.

Source: PDF p.3, paras2–4

This is a distinct assessment-year appeal

Although the Tribunal disposed of three years together, this judgment expressly confines itself to AY 2020-21. The August judgment concerned the other two years. The shared reasoning does not make ITA 121/2025 a duplicate disposal or permit importing another year’s delay duration into it.

Source: PDF pp.2–3

The result is procedural, with a final appellate effect

The first appeal remained barred, and the High Court closed this appeal and its pending applications. The order does not examine exemption eligibility, quantify additions or direct a fresh hearing. It should be used for its treatment of the unsupported delay explanation, not as a merits ruling against charitable status.

Source: PDF pp.2–4