Charitable public trust status upheld for temple management and worship activities, supporting reconsideration of registration.

A public trust whose objects were for the benefit of the public at large was treated as charitable, and its amended objects were upheld because they had been accepted and registered by the competent authority after inquiry under the Rajasthan Public Trust Act. Maintenance and management of temples, including worship and festivals according to the relevant sampradaya, was regarded as a charitable activity and not one confined to a particular religion or community. The objection based on section 13(1)(b) was therefore not accepted, and the trust was held entitled to reconsideration for registration under section 12AA, with the refusal set aside.

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Issues: Whether the assessee trust was entitled to registration under section 12AA of the Income-tax Act, 1961, in view of the nature of its objects, the amendments to the trust deed, and the objection based on section 13(1)(b) of the Income-tax Act, 1961.

Analysis: The trust was found to be a public trust and not a private trust, as its objects were for the benefit of the public at large. The additions made to the objects had been accepted and registered by the competent authority under the Rajasthan Public Trust Act, 1959, after inquiry, and were therefore not illegal. The original and added objects were held to be charitable in nature. Maintenance and management of temples, including performance of worship and festivals according to the relevant sampradaya, was treated as a charitable activity and not one confined to a particular religion or community. On that basis, the objection founded on section 13(1)(b) was not accepted.

Conclusion: The assessee was held entitled to reconsideration for grant of registration under section 12AA, and the refusal of registration was set aside.

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