2025 (9) TMI 1625

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.... of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). 2. The assessee has raised the following grounds in this appeal: - 1. Learned CIT(E) has erred in law and on the facts of the case in rejecting application for registration u/s. 80G of the Act. 2. Learned CIT(E) has erred in law and on the facts of the case in not appreciating that the trust activities are exclusively charitable, with no religious expenditure incurred since its inception. 3. Learned CIT(E) has erred in law and on the facts of the case in not appreciating that interpretation of Explanation 3 of section 80G does not bar trusts with incidental religious objects provided they adhere to Section 80G(5B). 3. Shri Mohit Balani, the....

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....f the Act defines charitable purpose, as per which "charitable purpose" does not include any purpose the whole or substantially the whole of which is of a religious nature. Thus, as per the definition of charitable purpose given in Section 80G of the Act, the charitable purpose should not include any purpose of substantial religious nature. The Ld. CIT(E) had reproduced the following object no-6 in his order which was held to be religious in nature and for which the registration under Section 80G(5) of the Act was denied to the assessee. Doing all kind of religious services, promoting and spreading sanatan dharma. To do the work of maintenance of divinity and belief and faith in the Gods and Goddesses among the people. To serve the....