SHRI RAM SHARNAM SABHA(REGD.),PANIPAT vs. CIT EXEMPTIONS, CHANDIGARH

Brief facts of the case are that assessee has filed an application for registration u/s 12AB(1)(b) of the Act and the registration was granted to the assessee as “Religious Entity”, therefore, aggrieved by the said registration, the assessee is in appeal before the Tribunal. It is prayed by the assessee that since the assessee society is carrying charitable activities of education and medical relief to poor and needy as

Heard both the parties and perused the materials available on record. The objects of the society are as under: “The aims and objects of the Society shall be purely for charitable and public welfare purposes. The following shall be the object of the Society a) To propogate and preach the religious teachings of shri Swami Satyanandji Maharaj as contained in Granth and Books written by him, to hold daily Satsang and periodical Sadhna Satsangs, and in order to inculcate religious ideas and Bhagtibhav among the public to arrange organize and hold lectures, study course, conferences and other functions. b) To organize, promote, set up, encourage, charitable, educational, and welfare institutions and libraries, for the public, without restrictions of colour, caste, creed or religion and to undertake and provide for the publication and printing of books, magazines, pamphlets etc. intended to disseminate religious and social knowledge amongst the public. c) To furtherance of the above objects to purchase land, construct buildings in India and to manage deal with them in manner in the best interest of the Society and to take grant and bonus from the Government, Local Bodies and other persons or organizations of the terms and conditions as may be deemed fit. d) To collect subscriptions and donations for the purpose of the Society, to open and maintain bank accounts, and to do all such acts as are conducive or incidental to the attainment of the above objects.” e) To provide financial and any other assistance for the medical treatment of poor and needy without any discrimination of caste, creed or religion. f) To grant scholarships, fellowships, awards, prizes and/or assist (financially or otherwise) any deserving candidate(s) / student(s) for attaining and/or for the attainment of better standards in education, without any regard to race, religion, creed of the beneficiaries; to aid, assist, manage, equip and take over, financially or otherwise, any public institution(s) and/or body(s) concerned with charitable work of any description; g) To promote, manage, construct, run, establish, improve, acquire, develop and / or assist in constructing, running, improving and/or developing clinics, hospitals, dispensaries, crèches, asylums, schools, colleges, universities, educational, technical and scientific institutions, research establishments, sporting, physical training, vocational training and industrial training institutions and centres;

It was the claim of the assessee that though the first object is in the nature of religious activities, however, other objects are related to the other charitable activity such as education and medical welfare etc. which are in the nature of general charitable activities. It is further observed that in Financial Year 2021-22 a sum of Rs.9,64,185/- were incurred for medical assistance and financial assistance for education; Rs.1,27,22,994/- was incurred in Financial Year 2022-23; Rs.1,26,99,744/- was incurred in Financial Year 2023-24 and Rs.10,64,209/- were incurred for Financial Year 2024-25 for the medical and education assistance. Thus, it cannot be said that the assessee society is wholly and exclusively engaged in the religious activities. This fact has been ignored by the Ld. CIT(A) and no opportunities was granted to the assessee before the restricting the registration as “religious entity”.

Under these circumstances in the larger interest of justice, we remit the matter back to the file of Ld. CIT(A) with the directions to examine the details filed by the

In the result, appeal of the assessee is allowed for statistical purposes. Order pronounced in the open Court on 15.07.2026.