Application seeking approval u/s 80G(5)(vi) rejected - Assessee...

Application seeking approval u/s 80G(5)(vi) rejected - Assessee is predominantly engaged in charitable activities - Some of the objects of the applicant/assessee are religious in nature - The Tribunal considered a CBDT Circular from 1999, which clarified the intent behind amending section 80G and emphasized that trusts primarily engaged in charitable activities could still benefit from section 80G despite incidental religious expenditures. Highlighting the absence of a show cause notice, the Tribunal underscored its significance in maintaining procedural fairness in tax proceedings, noting judicial precedents reinforcing the importance of such notices. - The Tribunal concluded that the rejection of the application by the CIT(E) was erroneous. It directed the granting of approval under section 80G(5) to the appellant trust.