2025 (9) TMI 635

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..... Though, the assessee has raised multiple grounds of appeal, however substantial ground of appeal relates to not allowing approval under section 80G(5) to assessee-trust by treating it as religious in nature. 2. Rival submission of both the parties heard and record perused. The Ld. Authorized Representative (ld.AR) of the assessee submits that assessee is a "trust" created in the year 1953 and in engaged in the services of poverty alleviation, providing medically, educational aid, upliftment of poor without any discrimination on the basis of cast, creed or religion. The assessee-trust is registered with Charity Commissioner. The assessee is having valid registration under section 12A/12AB of the Act. The assessee was allowed provisional r....

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....s much as possible for administration of Shree Gokulchandamaji Temple. Object as whole is to be considered and not in isolation of a particular word. Admittedly, the ld. CIT(E) has not examined the expenditure incurred for religious activities in last three financial years as per mandate of clauses (g) of sub-rule (2) of 11AA. The ld. AR of the assessee submits that he is ready to furnish account of all three preceding years wherein there is no such violation. The assessee has not spent any amount for religious purpose in last three financial years. Thus, the order passed by Ld.CIT(E) is not in consonance with prescribed under Rule-11AA. The Ld. AR of the assessee submits that assessee is an old trust and having provisional registration upt....