GIA INDIA,MUMBAI vs. A/DCIT (E) - 1(1), MUMBAI

ITA 5424/MUM/2025Status: DisposedITAT Mumbai11 November 2025AY 2012-13Bench: SHRI SAKTIJIT DEV (Vice President), MS PADMAVATHY S (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessee's activities constituted imparting "education" as per Section 2(15) and that the denial of exemption under Section 11 by the lower authorities was incorrect. Certain issues were remitted back to the AO for fresh consideration.

What were the facts?

The assessee, a non-profit entity providing education in gemmology, had its exemption under Section 11 denied by the AO and CIT(A). They argued that the assessee's activities were commercial in nature and hit by the proviso to Section 2(15) of the Income Tax Act.

What were the issues?

Whether the assessee's activities of providing training in gemmology qualify as 'education' for the purpose of charitable exemption under Section 2(15) and Section 11 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 2(15),Section 11,Section 12,Section 32,Section 234A,Section 234B

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Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SHRI SAKTIJIT DEY&

For Respondent: Shri. Swapnil Choudhary Sr. AR
Hearing: 29.10.2025Pronounced: 11.11.2025

Per Bench: These appeals by the assessee are against the separate orders of the Commissioner of Income Tax Appeals/National Faceless Appeal Centre (NFAC), Delhi passed u/s. 250 of the Income Tax Act, 1961 (the 'Act') for AYs 2010-11 to 2017-18. The issues contended by the assessee in all these appeals are common and therefore these appeals are heard together and disposed of through this common order. For the purpose of adjudication AY 2010-11 is considered as the lead case.

2.

The assessee is a company registere

The order continues below.

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