ACIT (Exemptions) Vs Vyakti Vikas Kendra India (ITAT Ahmedabad)
Sudarshan Kriya = Education & Medical Relief: ITAT Reaffirms 11 Exemption for Art of Living Trust
Revenue challenged deletion of additions made by AO on the ground that Assessee-trust’s Sudarshan Kriya programs were commercial & hit by 2(15) proviso, thereby denying exemptions u/s 11 & 12, capital expenditure, donations, corpus income & accumulations. Tribunal noted that all issues were already decided in favour of Assessee in its own earlier years (AYs 2011-12 to 2014-15, order dated 03.09.2019), where it was conclusively held that Sudarshan Kriya & structured yoga training constitute “imparting education” & “medical relief”, not business. Proviso to 2(15) therefore does not apply. Donations were voluntary & absence of profit motive established. Capital expenditure, application of income, donations to other registered trusts, corpus donations u/s 11(1)(d), accumulation u/s 11(2) & 15% deduction u/s 11(1)(a) were all correctly allowed by CIT(A). On exemption u/s 10(23C)(iiiad) for tribal-area schools, Tribunal upheld CIT(A)’s direction to AO to only verify conditions & allow. Revenue could not controvert any factual or legal findings. Entire appeal dismissed.
FULL TEXT OF THE ORDER OF ITAT AHMEDABAD
This appeal is filed by the Revenue against the order of the National Faceless Appeal Centre (NFAC), Delhi (in short “the CIT(A)”) dated 25.06.2025 for the Assessment Year (A.Y.) 2016-17 in the proceeding under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).
