2026 (1) TMI 1672

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....application for approval u/s 80G(5)(iii) of the Act. The Ld. CIT(E) found that one of the objects of the trust was religious in nature. Further, the assessee had also incurred religious expenditure in excess of prescribed limit of 5%. Therefore, the application of the assessee for approval u/s 80G(5) of the Act was rejected vide the impugned order. 3. Aggrieved with the order of the Ld. CIT(E), the assessee is in appeal before us. The following grounds have been taken in this appeal: 1.1 The order passed by U/s.80G(5) on 16.12.2024 by CIT(Exem). Ahmedabad rejecting the application for approval of the appellant trust u/s 80G(5)(ii) of the Act and cancelling the provisional approval by holding that the appellant trust was a religi....

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....ishnav does not represent any community but were believers of Lord Krishna. He explained that the facility of accommodation and food for the Vaishnav was irrespective of their caste, creed, community or sex. Therefore, the Ld. CIT(E) was not correct in treating this objective as religious in nature. Similarly, the objective of organizing Satsang for benefit of common people also can't be treated as religious in nature. As regards religious expense exceeding the limit of 5%, the Ld. AR submitted that the assessee could not furnish the detail of such expense before the Ld. CIT(E). He explained that all the celebration expenses, Granth Mahotsav printing expenses and decoration expenses were not religious in nature and the finding given by the ....

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.... the purpose for organising satsang is uplifting of the human life which will benefit the public at large. Similarly, the objective to provide accommodation and food for Vaishnavs also cannot be treated as religious in nature as such facility will be available to all the believers irrespective of their caste, creed, community or sex. Even if there is some element of religious activity in the form of performing daily worship, this is only subsidiary to the main objectives which are educational, medical aid and relief to the poor. The assessee is running a dedicated educational institutional for girls viz. Shri Ballav Acharya International Girls School, providing medical assistance and health care services to the under privileged by organisin....