GURDWARA COMMITTEE PATSHAHI 10,CHANDIGARH vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH, CHANDIGARH

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ITA 460/CHANDI/2026Status: DisposedITAT Chandigarh13 August 2026AY 2025-262 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that a similar issue regarding the definition of religious purpose and guidelines for approval was decided in a previous case. Following that precedent, the Tribunal restored the appeal back to the CIT(Exemptions) for re-examination.

What were the facts?

The assessee, a Gurudwara Committee, sought approval under Section 80G(5)(ii) for its trust. The CIT(Exemptions) rejected the application, citing that the trust's objects were substantially religious in nature, which Explanation 3 to Section 80G disallows for charitable purposes.

What were the issues?

Whether a trust whose objects are substantially religious in nature can be considered charitable for the purpose of Section 80G approval.

Which sections of the Income-tax Act were involved?

Section 80G

AI-generated summary — verify with the full judgment below

IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: HYBRID MODE BEFORE: SHRI MANOJ KUMAR AGGARWAL, AM & SH. RAJESH DAMODARLAL SHARMA, JM आयकर अपील सं./ ITA No. 460/Chd/2026 U/s 80G (A.Y. 2025-26) बनाम Gurudwara Committee Patshasi 10 CIT(Exemptions), C/0 Tej Mohan Singh (Advocate) Chandigarh 527, Sector 10-D, Chandigarh �ायी लेखा सं./PAN NO: AAAAG8430D अपीलाथ�/Appellant ��थ�/Respondent

िनधा�रती की ओर से/Assessee by : Sh. Tej Mohan Singh, Advocate राज� की ओर से/ Revenue by : Smt. Jaishree Sharma, CIT DR सुनवाई की तारीख/Date of Hearing : 05.08.2026 उदघोषणा की तारीख/Date of Pronouncement : 13.08.2026 आदेश/Order PER RAJESH DAMODARLAL SHARMA, J.M: 1. Aggrieved by rejection of an application as filed by the assessee seeking approval u/s 80G(5)(ii) vide impugned order dated 05.02.2026 of Ld. Commissioner of Income Tax (Exemption), Chandigarh, [CIT(E)], the assessee is in further appeal before us. 2. Upon perusal of and impugned order, it could be seen that the approval has been denied by Ld. CIT(E) by quoting the objects of the assessee-trust and by invoking Explanation 3 to Section 80G. It has finally been held that charitable

2 460/Chd/2026 purpose does not include a purpose the whole or substantially the whole of which is religious in nature. 3. During hearing, it was an admitted position that the similar issue has been decided by Tribunal in bunch of appeals titled as Shri Sanatan Dharam Venkuth Dharamsewa Samiti in ITA Nos.572/Chd/2026 & ors. common order dated 03.08.2026 defining the contours of religion and laying down certain guidelines for approval of such trusts. Respectfully following the same, we restore this appeal back to Ld. CIT(E) for examination on similar lines. 4. The appeal stand allowed for statistical purpose. Order pronounced on 13th August, 2026

-Sd- -Sd- (MANOJ KUMAR AGGARWAL) (RAJESH DAMODARLAL SHARMA) ACCOUNTANT MEMBER JUDICIAL MEMBER AS Dated: 13-08-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

BY ORDER ASSISTANT REGISTRAR INCOME TAX APPELLATE TRIBUNAL KENDRIYA SADAN, SECTOR – 9A CHANDIGARH

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