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2025 Supreme(Online)(ITAT) 6993

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Shri Sakthijit Dey, VP, Ms Padmavathy S, AM
GIA India – Appellant
Versus
The Income Tax Officer – Respondent


Advocates:
For the Appellants/Petitioners:Shri J.D. Mistry, Sr. Advocate & Shri Gunjan Kakkad
For the Respondents: Shri Swapnil Choudhary Sr. AR

Table of Content
1. facts regarding the appellant's educational activities (Para 1 , 2)
2. arguments regarding the nature of educational activities (Para 3 , 4 , 5 , 6)
3. court's observations on educational qualifications and provisions (Para 8 , 9 , 10 , 11)
4. clarification on the definition of education as per law (Para 12 , 13 , 14)
5. key conclusions on educational status for tax exemption (Para 15)
6. final decision and directions for appealed issues (Para 18 , 19 , 21)

ORDER

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 registered u/s. 25 of the Companies Act, 1956 and is a non-profit entity setup for imparting education in the field of gemmology, applied jewellery arts, jewellery design and manufacturing arts of diamond jewell

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