DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI vs. NATIONAL PAYMENT CORPORATION OF INDIA, MUMBAI

ITA 5328/MUM/2026Status: DisposedITAT Mumbai21 August 2026AY 2014-1516 pages
AI SummaryAllowed

What were the facts?

The assessee, National Payments Corporation of India (NPCI), claimed exemption under Section 11 and 12 for AY 2013-14 and 2014-15. The Assessing Officer rejected this claim, arguing that NPCI's activities of providing payment platform services for consideration fell under the proviso to Section 2(15) and were in the nature of trade, commerce, or business.

What did the Tribunal hold?

The Tribunal held that the dominant purpose test should be applied, and NPCI's activities were primarily for charitable purposes, even if some surplus was generated. The mere charging of fees for services did not disqualify it from exemption. The Tribunal also found no substance in the allegations of violating Section 13(1)(c)(ii).

What were the issues?

Whether NPCI's activities of providing payment platform services for consideration were in the nature of trade, commerce, or business, thereby attracting the proviso to Section 2(15) and disentitling it from exemption under Section 11 and 12.

Which sections of the Income-tax Act were involved?

Section 11,Section 12,Section 2(15),Section 13(1)(c)(ii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: SMT. BEENA PILLAI, HON’BLE & SMT. RATNA DASGUPTA, HON’BLE

PER SMT. BEENA PILLAI, JUDICIAL MEMBER:

Present appeals filed by revenue arises out of the orders dated 18/02/2026 passed by NFAC, Delhi [hereinafter referred to as “Ld.CIT(A)”] for A.Ys. 2013-14 & 2014-15. The grounds of appeal for both the Assessment years are identical except for variance in the quantum. Grounds of appeal for AY 2014-15 are extrac

The order continues below.

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