DAYANAND MATH,CHAMBA, HIMACHAL PRADESH vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH, CHANDIGARH

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ITA 24/CHANDI/2026Status: DisposedITAT Chandigarh06 August 2026AY 2025-262 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal followed a previous decision on a similar issue concerning the contours of religion and guidelines for approving such trusts. The appeal was restored to the CIT(E) for examination on similar lines.

What were the facts?

The assessee's application for approval under Section 80G(5)(ii) was rejected by the CIT(E). The rejection was based on the objects of the trust and Explanation 3 to Section 80G, stating that the purpose was substantially religious.

What were the issues?

Whether the objects of the trust are substantially religious, thereby disqualifying it for approval under Section 80G. The interpretation of 'charitable purpose' in relation to religious activities.

Which sections of the Income-tax Act were involved?

Section 80G(5)(ii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, CHANDIGARH

Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM आयकरअपीलसं. / ITA No.24/CHANDI/2026 Dayanand Math CIT(E) बनाम/ C/o Shri Tejmohan Singh (Advocate) Chandigarh – 160017 #527, Sector – 10D Vs. Chandigarh – 160011 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AAATD-7002-R (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Tej Mohan Singh (Advocate) – Ld. AR ��थ�कीओरसे/Respondent by : Smt. Jaishree Sharma (CIT) - Ld. DR (Virtual) सुनवाईकीतारीख/Date of Hearing : 05-08-2026 घोषणाकीतारीख /Date of Pronouncement 06-08-2026 : आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by rejection of an application as filed by the assessee seeking approval u/s 80G(5)(ii) vide impugned order dated 11.12.2025 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 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 06th August, 2026

-Sd- -Sd- (RAJESH DAMODARLAL SHARMA) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 06-08-2026 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

ASSISTANT REGISTRAR ITAT CHANDIGARH

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