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“advancement of general public utility”

Charitable TrustsSection 2(15)Section 2(15)173 judgments

The decision most relied on for advancement of general public utility is ACIT v. Ahmedabad Urban Development Authority (143 Taxmann.com 278), cited in 390 judgments on BharatTax.

Leading authorities on advancement of general public utility

ACIT v. Ahmedabad Urban Development Authority
143 Taxmann.com 278 · 2022 · Supreme Court
390
citing judgments

If activities for the advancement of general public utility are carried on as a business, income from such activities is not exempt under Section 11, even if the profits are utilized for the main charitable object. The argument that profits from general public utility activities can be ploughed back to charity to maintain exemption is not a good law.

CIT v. Andhra Chamber of Commerce
55 ITR 722 · 1965 · Supreme Court
167
citing judgments

An organization qualifies as having a charitable purpose if its primary object is the advancement of general public utility, even if its members receive incidental benefits. The existence of incidental non-charitable objects does not negate its charitable status.

India Trade Promotion Organization v. DGIT(Exemption)
371 ITR 333 · 2015 · High Court
128
citing judgments

An institution engaged in the advancement of general public utility retains its charitable character and eligibility for exemptions under Section 11 or approval under Section 10(23C)(iv) provided profit is not its predominant motive, even if it generates incidental surpluses or collects fees.

Khoday Distilleries Ltd. v. State of Karnataka
10 SCC 304 · 1996 · Reported
123
citing judgments

A 'trade' is primarily defined as the exchange of goods for goods or money, and secondarily as a business carried on with a view to profit. The term 'business' is more comprehensive than 'trade', encompassing manufacturing activities.

362 ITR 539 (Gujarat) (d) Institute of Chartered Accountants of India v. DGIT
347 ITR 99 · 2012 · High Court
112
citing judgments

The broad definition of 'business' should not be applied when interpreting the proviso to Section 2(15) of the Income-tax Act, 1961, as the object and purpose of the section must be considered.

(State of T.N v. Board of Trustees of the Port of Madras
4 SCC 630 · 1989 · Reported
108
citing judgments

An activity, even if it involves sales, does not constitute "business" for tax purposes if it is an incidental part of the main activities of a public utility entity and lacks a profit motive. The presence of a profit motive is generally essential to classify an activity as business.

Ahmedabad Urban Development Authority v. ACIT
396 ITR 323 · 2017 · High Court
108
citing judgments

Development authorities can continue to be regarded as existing for a 'Charitable Purpose' under Section 2(15) of the Income Tax Act, even after the introduction of the proviso to that section. The contention that such authorities automatically lose their charitable status due to the proviso is incorrect.

Institute of Chartered Accountants of India (ICAI) v. DGIT (Exemptions)
358 ITR 91 · 2013 · High Court
80
citing judgments

An institution carrying out charitable objects, such as education or advancement of general public utility, does not lose its Section 11 exemption merely by collecting fees for activities like campus placements or educational guidance, as this does not constitute carrying on a business.

Judgments citing advancement of general public utility

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)

conclusion that the proviso applies is misplaced. Even assuming, arguendo, that the assessee’s activities fall under “advancement of general public utility,” the condition precedent for invoking the proviso—receipts exceeding 20% of total income from commercial activities—is not satisfied, as delegate fees amount to only 12.6% of total

Micro Finance Industry Network, Gurgaon vs. CIT(E), Chandigarh

ITA 5879/DEL/2025[-]Status: DisposedITAT Delhi11 Mar 2026

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 12ASection 12A(1)(ac)Section 13(3)Section 80G

done efficiently, the same is not charitable rather it is a regulatory duty undertaken under the RBI supervision. The claim of advancement of general public utility is, therefore, absent in the case of the assessee, it operates solely through its membership base which comprises non- banking finance companies, micro finance

Micro Finance Industry Network, Gurgaon vs. CIT(E), Chandigarh

ITA 5878/DEL/2025[-]Status: DisposedITAT Delhi11 Mar 2026

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 12ASection 12A(1)(ac)Section 13(3)Section 80G

done efficiently, the same is not charitable rather it is a regulatory duty undertaken under the RBI supervision. The claim of advancement of general public utility is, therefore, absent in the case of the assessee, it operates solely through its membership base which comprises non- banking finance companies, micro finance

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner Income Tax, Exemptions, Circle-1, Bangalore

ITA 355/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

powers are frame all with a view to achieve industrial development in Karnataka. Development of industries has been construed to be ‘advancement of general public utility' by the Apex Court. Activities of the assessee are therefore to be regarded as covered within the operative provisions of section

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner of Income-Tax, Exemptions, Circle-1, Bangalore

ITA 354/BANG/2024[2016-17]Status: DisposedITAT Bangalore02 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

powers are frame all with a view to achieve industrial development in Karnataka. Development of industries has been construed to be ‘advancement of general public utility' by the Apex Court. Activities of the assessee are therefore to be regarded as covered within the operative provisions of section

Chhattisgarh Housing Board, Raipur vs. Exemption Circle, Raipur

In the result, this appeal of the assessee is allowed as above for statistical purposes

ITA 653/RPR/2025[2017-18]Status: DisposedITAT Raipur17 Feb 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR
Section 11Section 12ASection 250

income and expenditure statement furnished by it before AO. 6.2.2 During the assessment proceedings the AO examined the issue of advancement of general public utility in the case of the appellant. The discussion made by AO with respect to the advancement of general public utility is reproduced: ........................................................................ …………………………………………………… Since the contract

Chhattisgarh Housing Board, Raipur vs. Exemption Circle, Raipur

In the result, this appeal of the assessee is allowed as above for statistical purposes

ITA 652/RPR/2025[2016-17]Status: DisposedITAT Raipur17 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR
Section 11Section 12ASection 250

income and expenditure statement furnished by it before AO. 6.2.2 During the assessment proceedings the AO examined the issue of advancement of general public utility in the case of the appellant. The discussion made by AO with respect to the advancement of general public utility is reproduced: ........................................................................ …………………………………………………… Since the contract

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

In the result, this appeal of the assessee is allowed as above for statistical purposes

ITA 651/RPR/2025[2013-14]Status: DisposedITAT Raipur17 Feb 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR
Section 11Section 12ASection 250

income and expenditure statement furnished by it before AO. 6.2.2 During the assessment proceedings the AO examined the issue of advancement of general public utility in the case of the appellant. The discussion made by AO with respect to the advancement of general public utility is reproduced: ........................................................................ …………………………………………………… Since the contract

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

In the result, this appeal of the assessee is allowed as above for statistical purposes

ITA 650/RPR/2025[2012-13]Status: DisposedITAT Raipur17 Feb 2026AY 2012-13

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR
Section 11Section 12ASection 250

income and expenditure statement furnished by it before AO. 6.2.2 During the assessment proceedings the AO examined the issue of advancement of general public utility in the case of the appellant. The discussion made by AO with respect to the advancement of general public utility is reproduced: ........................................................................ …………………………………………………… Since the contract

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

In the result, this appeal of the assessee is allowed as above for statistical purposes

ITA 649/RPR/2025[2011-12]Status: DisposedITAT Raipur17 Feb 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR
Section 11Section 12ASection 250

income and expenditure statement furnished by it before AO. 6.2.2 During the assessment proceedings the AO examined the issue of advancement of general public utility in the case of the appellant. The discussion made by AO with respect to the advancement of general public utility is reproduced: ........................................................................ …………………………………………………… Since the contract

Centre for E-Governance, Bangalore vs. DCIT, Exemption, Circle-1, Bangalore

ITA 936/BANG/2025[2021-22]Status: DisposedITAT Bangalore31 Dec 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

For Appellant: Shri S Parthasarthi, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 11Section 11(1)(a)Section 12ASection 2(15)

such projects. Therefore, the assessee contended that the interest income was directly linked with the charitable objects of the society, which involved advancement of general public utility within the meaning of section 2(15) of the Act. 7. On examination of the Receipts & Payments Account and the Income & Expenditure Account

The Mysore Association Bombay, Matunga - Mumbai vs. Income Tax Officer Exemption Ward 2(4), Mumbai, Lal Baug, Parel

In the result, the appeal of the Assessee is partly allowed

ITA 5860/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Dec 2025AY 2014-15

Bench: JUSTICE (RETD.) C. V. BHADANG (President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri Kavan N. Limbasiya, Sr.DR
Section 11Section 12ASection 250

auditorium and conference hall which is given on rent with the motive of earning profit and, therefore, the assessee is involved in advancement of general public utility with a profit motive and the Assessing officer thereafter denied claim of exemption u/s 11 of the Act. 3. The assessee thereafter carried

Jharkhand Industries & Trade Assiciation, Dhanbad vs. CIT, Exemption, Patna

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

ITA 328/RAN/2024[AY 2024-25]Status: DisposedITAT Ranchi12 Nov 2025

Bench: Shri Pradip Kumar Choubey & Shri Ratnesh Nandan Sahayi.T.A. Nos.307, 327 & 328/Ran/2024 Assessment Years: 2022-23, 2023-24 & 2024-25 Jharkhand Industries & Trade Association............................……….……Appellant Tiwari Market, Bank More, Tiwari Gali, Dhanbad, Jharkhand – 826001. [Pan: Aacaj6085D] Vs. Cit (Exemption), Patna.....…...…..….…..….........……........……...…..…..Respondent Appearances By: Shri M. K. Choudhury, Ar, Appeared On Behalf Of The Appellant. Shri Swaroop Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 12, 2025 Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2022-23, 2023-24 & 2024-25 Against Separate Orders All Dated 25.05.2024 Of The Commissioner Of Income Tax (Exemption), Patna [Hereinafter Referred To As ‘Cit(E)’] Rejecting The Application Filed In Form 10Ab For Grant Of Regular Registration U/S 12A(1)(Ac)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.307/Ran/2024 Is Taken As Lead Case For Narration Of Facts.

Section 11Section 12ASection 12A(1)(ac)Section 2(15)

Nos.307, 327 & 328/Ran/2024 Jharkhand Industries & Trade Association 12A(1)(ac)(vi) of the Act on 07.04.2022. The assessee society is involved in advancement of general public utility. The assessee filed an application in Form 10AB on 29.11.2023 for registration u/s 12A(1)(ac)(iii) of the Act but the same ... registered society and the assessee has been granted provisional registration u/s 12A of the Act and the assessee society was involved in advancement of general public utility. The assessee filed an application in Form 10AB on 29.11.2023 for regular registration u/s 12A of the Act. We also find that

Jharkhand Industries & Trade Association, Dhanbad vs. CIT, Exemption, Patna

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

ITA 327/RAN/2024[2023-24]Status: DisposedITAT Ranchi12 Nov 2025AY 2023-24

Bench: Shri Pradip Kumar Choubey & Shri Ratnesh Nandan Sahayi.T.A. Nos.307, 327 & 328/Ran/2024 Assessment Years: 2022-23, 2023-24 & 2024-25 Jharkhand Industries & Trade Association............................……….……Appellant Tiwari Market, Bank More, Tiwari Gali, Dhanbad, Jharkhand – 826001. [Pan: Aacaj6085D] Vs. Cit (Exemption), Patna.....…...…..….…..….........……........……...…..…..Respondent Appearances By: Shri M. K. Choudhury, Ar, Appeared On Behalf Of The Appellant. Shri Swaroop Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 12, 2025 Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2022-23, 2023-24 & 2024-25 Against Separate Orders All Dated 25.05.2024 Of The Commissioner Of Income Tax (Exemption), Patna [Hereinafter Referred To As ‘Cit(E)’] Rejecting The Application Filed In Form 10Ab For Grant Of Regular Registration U/S 12A(1)(Ac)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.307/Ran/2024 Is Taken As Lead Case For Narration Of Facts.

Section 11Section 12ASection 12A(1)(ac)Section 2(15)

Nos.307, 327 & 328/Ran/2024 Jharkhand Industries & Trade Association 12A(1)(ac)(vi) of the Act on 07.04.2022. The assessee society is involved in advancement of general public utility. The assessee filed an application in Form 10AB on 29.11.2023 for registration u/s 12A(1)(ac)(iii) of the Act but the same ... registered society and the assessee has been granted provisional registration u/s 12A of the Act and the assessee society was involved in advancement of general public utility. The assessee filed an application in Form 10AB on 29.11.2023 for regular registration u/s 12A of the Act. We also find that

Jharkhand Industries & Trade Association, Dhanbad vs. CIT (Exemption), Patna

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

ITA 307/RAN/2024[2022-23 to 2024-25]Status: DisposedITAT Ranchi12 Nov 2025

Bench: Shri Pradip Kumar Choubey & Shri Ratnesh Nandan Sahayi.T.A. Nos.307, 327 & 328/Ran/2024 Assessment Years: 2022-23, 2023-24 & 2024-25 Jharkhand Industries & Trade Association............................……….……Appellant Tiwari Market, Bank More, Tiwari Gali, Dhanbad, Jharkhand – 826001. [Pan: Aacaj6085D] Vs. Cit (Exemption), Patna.....…...…..….…..….........……........……...…..…..Respondent Appearances By: Shri M. K. Choudhury, Ar, Appeared On Behalf Of The Appellant. Shri Swaroop Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 12, 2025 Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2022-23, 2023-24 & 2024-25 Against Separate Orders All Dated 25.05.2024 Of The Commissioner Of Income Tax (Exemption), Patna [Hereinafter Referred To As ‘Cit(E)’] Rejecting The Application Filed In Form 10Ab For Grant Of Regular Registration U/S 12A(1)(Ac)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.307/Ran/2024 Is Taken As Lead Case For Narration Of Facts.

Section 11Section 12ASection 12A(1)(ac)Section 2(15)

Nos.307, 327 & 328/Ran/2024 Jharkhand Industries & Trade Association 12A(1)(ac)(vi) of the Act on 07.04.2022. The assessee society is involved in advancement of general public utility. The assessee filed an application in Form 10AB on 29.11.2023 for registration u/s 12A(1)(ac)(iii) of the Act but the same ... registered society and the assessee has been granted provisional registration u/s 12A of the Act and the assessee society was involved in advancement of general public utility. The assessee filed an application in Form 10AB on 29.11.2023 for regular registration u/s 12A of the Act. We also find that

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

assessee. After perusing the various details furnished by the assessee the AO held that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities ... under section 10(23C) of the Act if they carry on commercial activities. The activities of the appellant are of advancement of general public utility nature and it had conducted various courses throughout the year in exchange of consideration for imparting the training to them, it is hit by first

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

assessee. After perusing the various details furnished by the assessee the AO held that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities ... under section 10(23C) of the Act if they carry on commercial activities. The activities of the appellant are of advancement of general public utility nature and it had conducted various courses throughout the year in exchange of consideration for imparting the training to them, it is hit by first

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

assessee. After perusing the various details furnished by the assessee the AO held that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities ... under section 10(23C) of the Act if they carry on commercial activities. The activities of the appellant are of advancement of general public utility nature and it had conducted various courses throughout the year in exchange of consideration for imparting the training to them, it is hit by first

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

assessee. After perusing the various details furnished by the assessee the AO held that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities ... under section 10(23C) of the Act if they carry on commercial activities. The activities of the appellant are of advancement of general public utility nature and it had conducted various courses throughout the year in exchange of consideration for imparting the training to them, it is hit by first

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

assessee. After perusing the various details furnished by the assessee the AO held that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities ... under section 10(23C) of the Act if they carry on commercial activities. The activities of the appellant are of advancement of general public utility nature and it had conducted various courses throughout the year in exchange of consideration for imparting the training to them, it is hit by first