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The ITAT held that the assessee-institution qualifies as a charitable entity engaged in "education" within the meaning of section 2(15) and is entitled to exemption under section 11. It found that systematic instruction in gemology through a structured curriculum, formal classes, fixed timings, fee structure, professional faculty, discipline, vacations, and evaluation leading to certification constitutes imparting education, irrespective of affiliation to a university. The Tribunal rejected the Revenue's contention that the assessee's activities fell under "advancement of any other object of general public utility" and that the proviso to section 2(15) applied, and distinguished the precedent relied upon by the Revenue, thereby overturning the denial of exemption by lower authorities.
The ITAT held that the assessee-institution qualifies as a charitable entity engaged in "education" within the meaning of section 2(15) and is entitled to exemption under section 11. It found that systematic instruction in gemology through a structured curriculum, formal classes, fixed timings, fee structure, professional faculty, discipline, vacations, and evaluation leading to certification constitutes imparting education, irrespective of affiliation to a university. The Tribunal rejected the Revenue's contention that the assessee's activities fell under "advancement of any other object of general public utility" and that the proviso to section 2(15) applied, and distinguished the precedent relied upon by the Revenue, thereby overturning the denial of exemption by lower authorities.
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