Section 80G approval turns on an institution's objects,...

Section 80G approval turns on an institution's objects, beneficiaries and activities considered as a whole, rather than isolated spiritual or philosophical clauses. Disseminating Bhagavad Gita teachings alongside relief of poverty, medical relief, public welfare, libraries and reading rooms does not make a society wholly or substantially religious where membership and services are open to all communities. Religious-expenditure entries in Form 10AB that duplicated total audited expenditure, despite a declaration of no religious spending, were treated as an inadvertent data-entry error rather than a substantive admission. In any event, incidental religious expenditure below the five per cent statutory ceiling does not defeat eligibility. The rejection was set aside and approval was directed to be granted.