DIT v. Ahmedabad Management Association

366 ITR 85High Court2014#3279 most cited

What is DIT v. Ahmedabad Management Association authority for?

Educational activities, including Continuing Education Diploma and Certificate Programmes, Management Development Programmes, and Public Talks, Seminars, Workshops, and Conferences, are considered activities in the field of education for the purpose of exemption under the Income-tax Act. The meaning of 'education' under Section 2(15) is not restricted to scholastic education but encompasses a broader scope.

36

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2015 to 2026.

Also referred to as

DIT v. Ahmedabad Management Association · Section 2(15) · education · advancement of general public utility · charitable activities · educational activities · Continuing Education Diploma · Management Development Programme · Public Talks · Seminars · Workshops · Conferences

Sections most often in play

Section 2(15)Section 11Section 11(4)Section 234ASection 234BSection 32Section 10(23C)Section 12

Issues it is cited on

section 10(22)advancement of general public utilitysection 11(4)section 124(1)section 10(23)section 10(23c)(iv)proviso to section 2(15)section 10(23c)(vi)section 11(4a)section 13(8)credit for tdssection 2(15)

Judgments citing DIT v. Ahmedabad Management Association

Maha Acadamy of Pediatric Neurology, Nagpur vs. CIT(Exemption), Pune

In the result, appeal filed by the assessee stands allowed

ITA 217/NAG/2025[2025-26]Status: DisposedITAT Nagpur26 Mar 2026AY 2025-26

Bench: Shri Pawan Singh & Shri Khettra Mohan Roymaha Academy Of Pediatric Cit (Exemptions), Pune Neurology, Plot No.7, Block Vs Nos. 2, 3, 4, 5, Guru Balawantsing Compound, Near Lokmat Building, Patwardhan Ground, Nagpur-440012. Pan : Aaqam 4626 H Assessee Respondent Assessee By : Shri Pranav Ashtikar, Ca Revenue By : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 24.02.2026 Date Of Pronouncement : 26.03.2026

For Appellant: Shri Pranav Ashtikar, CAFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 12Section 12ASection 12A(1)(ac)

…formal schooling but also systematic dissemination of knowledge through seminars, workshops, and continuing education programmes. (Maha Academy of Pediatric Neurology) 17. The Hon’ble Gujarat High Court in DIT (Exemption) v. Ahmedabad Management Association (366 ITR 85) held that conducting management development programmes, public talks, and conferences amounts to educational activity. Similarly, in CIT (Exemption) v. Anesthesia Society (260 Taxman 375), the Rajasthan High Court held that organising medical seminars and research conferences constitutes charitable activity even if primarily attended by medical p…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5429/MUM/2025[2017-18]Status: DisposedITAT Mumbai11 Nov 2025AY 2017-18

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5428/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Nov 2025AY 2016-17

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5427/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Nov 2025AY 2015-16

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5426/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Nov 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5425/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Nov 2025AY 2013-14

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5424/MUM/2025[2012-13]Status: DisposedITAT Mumbai11 Nov 2025AY 2012-13

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5423/MUM/2025[2011-12]Status: DisposedITAT Mumbai11 Nov 2025AY 2011-12

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5422/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Nov 2025AY 2010-11

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…t could not be said that the assessee was carrying out any 'education' activity. In this context, we may refer to the judgment of the Hon'ble Gujarat High Court in the case of DIT(E) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85, wherein the association undertook multifaceted activity, viz. conducting continuing education, Diploma & Certificate programme, Management Development programmes, public talks, seminars, workshops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'…

Neuro Update Chennai, Chennai vs. ITO, Exemption Ward-1, Chennai

In the result, the appeal of the assessee is allowed

ITA 1480/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Oct 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

For Appellant: Shri. G. Sitharaman, CA &For Respondent: Shri. R. Raghupathy, Addl. C.I.T
Section 11Section 12ASection 2(15)Section 250

…lify for an exemption even if it is of a rarified nature (copies of the judgment enclosed in Annexure 5 (pages 93 to 96). C. The decision of the High Court of Gujarat in the case of Director of Income-tax (Exemption) v. Ahmedabad Management Association [2014] 366 ITR 85 wherein it was held in Paragraph 5.6 that "Now applying the ratio of the decision of the Division Bench of this Court in the case of Gujarat State Co-operative Union (Supra) reproduced hereinabove and the activities of the assessee such as Continuing Education Diploma and Certificate Programme; Management Development Programme; Public Talks and Se…

St. Joseph'S Education and Medical Relief Society, Mumbai vs. Asstt. Director of Income Tax -(E)-II(1), Mumbai

ITA 2509/MUM/2024[2010-11]Status: DisposedITAT Mumbai30 Oct 2024AY 2010-11

Bench: Smt Beena Pillai & Smt Renu Jauhri

Section 12ASection 80G

…tion 2 (15) is not applicable to the assessee and assessee is entitled to the benefit of exemption under section 11 of the act. He vehemently reliance on the decision of Hon'ble Gujarat High Court in case of DIT vs Ahmedabad Management Association reported in 366 ITR 85, wherein it was held that on fair reading of section 2 (15) of the act, the newly inserted proviso to section 2 (15) of the act will not apply in respect of relief to the poor, education or medical relief. Thus where the purpose of trust institution is relief to the poor, education or medical relief, it will constitute “charitable purpose”, even i…

City As Lab Foundation, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 2025/MUM/2024[2024-25]Status: DisposedITAT Mumbai30 Oct 2024AY 2024-25

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGARWAL (Accountant Member)

Section 124(1)(ac)Section 12ASection 8(1)

…ee cannot be an educational activity. We need not labour much to decide this issue, as we are benefited by the decision of the High Court of Gujarat in the case of DIT (Exemptions) v. Ahmedabad Management. Association [2014] 47. taxmann.com 162/255 Taxman 223/366 ITR 85 (Gul. The Court considered the decision in Sote Trustee Loka Shikshane Trust (supra), as it was argued by the Revenue as is done before us that the activity is not education as explained in Sole Trustee Loka Shikshana Trust (supra) and it was held as follows:- 5.4 Now while considering whether the activities of the assessee can be said to be educa…

City As Lab Fondation, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 2023/MUM/2024[2024-25]Status: DisposedITAT Mumbai30 Oct 2024AY 2024-25

Bench: SHRI AMIT SHUKLA (Judicial Member)

Section 124(1)(ac)Section 12ASection 8(1)

…ee cannot be an educational activity. We need not labour much to decide this issue, as we are benefited by the decision of the High Court of Gujarat in the case of DIT (Exemptions) v. Ahmedabad Management. Association [2014] 47. taxmann.com 162/255 Taxman 223/366 ITR 85 (Gul. The Court considered the decision in Sote Trustee Loka Shikshane Trust (supra), as it was argued by the Revenue as is done before us that the activity is not education as explained in Sole Trustee Loka Shikshana Trust (supra) and it was held as follows:- 5.4 Now while considering whether the activities of the assessee can be said to be educa…

M.P.Madhyam, Bhopal vs. The DCIT Exemption, Bhopal

In the result, appeals of assessee for A

ITA 427/IND/2022[2017-18]Status: DisposedITAT Indore31 Aug 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 13(8)Section 143(3)Section 147Section 2(15)Section 234D

…e date copy of this order is received. The writ petition stands disposed of. There will be no orders as to cost." Further, learned Counsel for the assessee also relied on the ratio laid down in the cases of DIT (E) vs. Ahmedabad Management Association [2014] 366 ITR 85 (Guj H.C.); National Horticulture Board vs. ACIT [2015] 53 taxmann.com 343 (Delhi Trib.) and Institute for Development & Research in banking Technology vs. ADIT(E-1) [2015] 63 taxmann.com 297 (Hyderabad Tribunal.). 9. We have given our thoughtful consideration to the facts of the present case and the case-laws relied upon by the parties. We find…

M.P.Madhyam, Bhopal vs. The ACIT Exemption, Bhopal

In the result, appeals of assessee for A

ITA 425/IND/2022[2016-17]Status: DisposedITAT Indore31 Aug 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 13(8)Section 143(3)Section 147Section 2(15)Section 234D

…e date copy of this order is received. The writ petition stands disposed of. There will be no orders as to cost." Further, learned Counsel for the assessee also relied on the ratio laid down in the cases of DIT (E) vs. Ahmedabad Management Association [2014] 366 ITR 85 (Guj H.C.); National Horticulture Board vs. ACIT [2015] 53 taxmann.com 343 (Delhi Trib.) and Institute for Development & Research in banking Technology vs. ADIT(E-1) [2015] 63 taxmann.com 297 (Hyderabad Tribunal.). 9. We have given our thoughtful consideration to the facts of the present case and the case-laws relied upon by the parties. We find…

M.P.Madhyam, Bhopal vs. The ACIT Exemption, Bhopal

In the result, appeals of assessee for A

ITA 423/IND/2022[2013-14]Status: DisposedITAT Indore31 Aug 2023AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 13(8)Section 143(3)Section 147Section 2(15)Section 234D

…e date copy of this order is received. The writ petition stands disposed of. There will be no orders as to cost." Further, learned Counsel for the assessee also relied on the ratio laid down in the cases of DIT (E) vs. Ahmedabad Management Association [2014] 366 ITR 85 (Guj H.C.); National Horticulture Board vs. ACIT [2015] 53 taxmann.com 343 (Delhi Trib.) and Institute for Development & Research in banking Technology vs. ADIT(E-1) [2015] 63 taxmann.com 297 (Hyderabad Tribunal.). 9. We have given our thoughtful consideration to the facts of the present case and the case-laws relied upon by the parties. We find…

M/S M.P. Madhyam, Bhopal vs. The ACIT Exemption, Bhopal

In the result, appeals of assessee for A

ITA 422/IND/2022[2011-12]Status: DisposedITAT Indore31 Aug 2023AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 13(8)Section 143(3)Section 147Section 2(15)Section 234D

…e date copy of this order is received. The writ petition stands disposed of. There will be no orders as to cost." Further, learned Counsel for the assessee also relied on the ratio laid down in the cases of DIT (E) vs. Ahmedabad Management Association [2014] 366 ITR 85 (Guj H.C.); National Horticulture Board vs. ACIT [2015] 53 taxmann.com 343 (Delhi Trib.) and Institute for Development & Research in banking Technology vs. ADIT(E-1) [2015] 63 taxmann.com 297 (Hyderabad Tribunal.). 9. We have given our thoughtful consideration to the facts of the present case and the case-laws relied upon by the parties. We find…

Sarswati Vidhya Pratishthan M.P, Bhupal vs. The ACIT 2(1), Bhopal

In the result, appeal of assessee is allowed

ITA 392/IND/2022[2012-13]Status: DisposedITAT Indore30 Aug 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisarswati Vidhya Pratishthan Dcit (E) M.P. Bhopal Vs. 01, Harshwardhan Nagar Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aadas0899M Assessee By Shri Santosh Deshmukh & Shri Parth Jhawar, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.08.2023 Date Of Pronouncement 30.08.2023

Section 11Section 11(1)(a)Section 12ASection 143Section 143(3)Section 263

…Income-tax (Exemptions) iii. Credai Bengal V. ITO (Exemptions), Ward-1(1), Kolkata [2019] 110 taxmann.com 113 (Kolkata - Trib.) iv. Gujarat High Court in the case of DIT (Exemption) v. Ahmedabad Management Association [2014] 47 taxmann.com 162/225 Taxman 223/366 ITR 85 4. On the other hand, Ld. DR has submitted that the expenditure in question has been incurred by the assessee on the occasion of Silver Jubilee Celebration which shows that it has nothing to do with the objects and activity of the assessee to promote or impart education. The expenditure has not been incurred by the assesse for achieving the objec…

Umak Education Trust, Delhi vs. JCIT (E), Range- 2, Delhi

ITA 690/DEL/2019[2014-15]Status: DisposedITAT Delhi02 Nov 2022AY 2014-15

Bench: Shri Anil Chatrurvedi & Shri Anubhav Sharmaumak Education Trust, Vs. Jcit(E), S-135, Greater Kailash Ii, Range-2, New Delhi Delhi (Appellant) (Respondent) Pan: Aaatu2598P

For Appellant: Ms. Kanika Jain, CAFor Respondent: Shri Abhishek Kumar, Sr. DR
Section 11Section 12ASection 142(1)Section 143(2)Section 143(3)Section 194Section 194JSection 80G(5)(vi)

…oning. In this context she refered to following judgments:- • 250 ITR 504 (Del) CIT v. Shri Ram Education Foundation • 252 ITR 837 (Guj) CIT v. Shri Lai Bahadur Shastri Education Society • 369 ITR 645 (Bom) DIT v. Samudra Institute of Maritime Studies Trust • 366 ITR 85 (Guj) DIT v. Ahmedabad Management Association • 74 TTJ 177 (Mum) St. Joseph Technical School v. Asstt. DIT • 154 ITD 10 (Del) Praxis Institute of Participatory Practices v. DIT • 70 SOT 443 (Hyd) Water and Land Management Training and Research 25 Institute v. DIT • Gujarat State Co-operative Union v. CIT reported in 195 ITR 279” UMAK Education Tru…

Gujarat Safety Council, Vadodara vs. The Income Tax Officer, Exemption Ward, Vadodara

In the result, Ground No.1 of the assessee’s appeal is allowed

ITA 485/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

For Appellant: Parin Shah, A.Rs
Section 1Section 11Section 2(15)

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘SMC’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, AHMEDABAD BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI MAHAVIR PRASAD, JUDICIAL MEMBER आयकर अपील सं./I.T.A. No. 485/Ahd/2018 & 712/Ahd/2017 ("नधा"रण वष" / Assessment Years : 2012-13 & 2011-12) Gujarat Safety Council बनाम/ Income Tax Officer 4th Floor, Mid Way Height, Exemption Ward, Income Vs. B/s. Hanuman Temple, Nr. Tax Office, Vadodara Kirti Mandir, Kalaghoda, Vadodara 390001 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAATG0943L .. (अपीलाथ" /Appellant) (""यथ" / Respondent) Shri S. N. Soparkar…

DIT v. Ahmedabad Management Association (366 ITR 85) — Cited in 36 Judgments | BharatTax