High Court of Judicature for Rajasthan · Judgments and reasoned final orders
Commissioner of Income Tax (Exemptions), Jaipur v. Jaipur Development Authority (and Connected Appeals)
D.B. Income Tax Appeal Nos. 150/2017, 284/2010, 151/2017, 152/2017, 349/2017, 45/2018 & 254/2018 ·
Charitable exemption under Section 11 read with Section 2(15) proviso for a statutory urban development authority on Supreme Court remand following Ahmedabad Urban Development Authority (2022) 449 ITR 1 (SC); consequential relief under Sections 11(2), 11(3), and 13(8).
1. FACTS OF THE CASE
Revenue filed seven appeals challenging ITAT orders granting registration and exemption under Sections 11 and 12A to Jaipur Development Authority (JDA), a statutory urban development body constituted under the Jaipur Development Authority Act, 1982. Earlier dismissals had been remanded by the Supreme Court to verify applicability of ACIT (Exemptions) v. Ahmedabad Urban Development Authority (2022) 449 ITR 1 (SC).
2. DISCUSSION BY THE COURT
The Division Bench noted that in Ahmedabad Urban Development Authority (para 253 D.1), the Supreme Court expressly affirmed the Rajasthan High Court decisions in CIT v. Jodhpur Development Authority (2016) 287 CTR 473 (Raj) and CIT v. Jaipur Development Authority, holding that statutory urban development authorities perform objects of general public utility under Section 2(15) and are entitled to exemption under Section 11. Once the primary issue of registration and Section 11 eligibility stands affirmed in favour of JDA, the ancillary questions regarding accumulation under Sections 11(2) and 11(3) and operation of Section 13(8) also stand answered in the assessee's favour.
3. JUDICIAL DECISION
Dismissing all seven Revenue appeals, the High Court held that no substantial question of law survived in light of the Supreme Court declaration in Ahmedabad Urban Development Authority and confirmed the ITAT orders granting Section 11 exemption and consequential benefits under Sections 11(2), 11(3), and 13(8).
4. OUTCOME
Assessee - All seven Revenue appeals dismissed; ITAT orders upholding Section 11 exemption for Jaipur Development Authority affirmed.
5. AKHB REVIEW POINT
For statutory development and housing authorities, Ahmedabad Urban Development Authority (2022) 449 ITR 1 (SC) settles that regulatory and statutory town-planning functions qualify as advancement of general public utility under Section 2(15), carrying consequential entitlement to accumulation benefits under Sections 11(2) and 11(3).
Source and verification
7-page official High Court of Judicature for Rajasthan judgment PDF (20260122_RJHC020962072017.pdf, 99,345 bytes).
Original PDF: 7 pages · SHA-256: c98608be840ee669996ffbbc3d35a225fd087453f3520ddea66302e4f0ebcd23
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies Sections 2(15), 11, 11(2), 11(3), 12A, and 13(8) of the Income-tax Act, 1961. Income-tax Act, 2025 equivalence is not verified.
Full 7-page primary judgment PDF text read and verified page-by-page. Decided on remand from the Supreme Court applying ACIT (Exemptions) v. Ahmedabad Urban Development Authority (2022) 449 ITR 1 (SC).
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General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.