MAHA PIDI ARISI THITTAM VEDA RAKSHANAM TRUST,CHENNAI vs. CIT EXEMPTION, CHENNAI

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ITA 2604/CHNY/2026Status: DisposedITAT Chennai04 August 20267 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(E) did not properly examine the dominant objects and the true nature of the trust's activities. Mere description or expenditure on certain rituals does not automatically disqualify a trust from 80G approval if the activities are essentially charitable and for public benefit.

What were the facts?

The assessee, a trust, applied for approval under Section 80G of the Income Tax Act. The CIT(E) rejected the application, citing that the trust incurred over 5% of its expenditure on religious activities (Vedic programmes and rituals). The assessee contended that these activities were primarily charitable and for public welfare.

What were the issues?

Whether the trust's activities, including Vedic programmes and rituals, are predominantly charitable or religious in nature 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

Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & SHRI INTURI RAMA RAO

Hearing: 04.08.2026Pronounced: 04.08.2026

आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Exemption), Chennai dated 18.03.2026, rejecting Form No.10AB filed for seeking approval u/s.80G of the Income Tax Act, 1961 (hereinafter the ‘Act’).

- 2 - ITA No.2604/CHNY/2026 Maha Pidi Arisi Thittam Veda Rakshanam Trust 2. Brief facts of the case are as follows:- The assessee is a trust. It filed an online application in Form No.10AB on 30.09.2025 seeking approval u/s.80G of the Act. During the course of proceedings, the CIT(E) issued a show-cause notice stating that, based on the documents furnished, the activities of the assessee-trust appeared to be religious-cum-charitable in nature. In response, the assessee submitted that the predominant portion of its expenditure was incurred towards charitable activities and advancement of an object of general public utility, and only about 16% of the expenditure related to ritual and Vedic programmes. However, the CIT(E) rejected the application for approval u/s. 80G of the Act on the ground that the assessee had incurred more than 5% of its expenditure towards religious activities and was, therefore, not eligible for approval u/s. 80G of the Act.

3.

Aggrieved, the assessee has filed the present appeal before the Tribunal. Before us, the Ld. AR submitted that the CIT(E) erred in rejecting the assessee's application for approval u/s. 80G of the Act by treating the trust as a religious trust merely because the assessee had described itself as a "religious-cum-charitable trust" in Form No.10AB. He submitted that the dominant objects and activities of the trust are charitable in nature and not religious. Merely because certain activities involve Vedic programmes or rituals would not alter the charitable

- 3 - ITA No.2604/CHNY/2026 Maha Pidi Arisi Thittam Veda Rakshanam Trust character of the trust. The dominant purpose of the trust is education, relief to the poor, advancement of general public utility and welfare of the public, which satisfies the test laid down by the Hon'ble Rajasthan High Court in Umaid Charitable Trust v. Union of India reported in 307 ITR 226.

4.

The Ld. AR further submitted that the CIT(E) rejected the application solely on the ground that approximately 16% of the expenditure was incurred towards ritual and Vedic programmes, without appreciating the nature and purpose of such expenditure. He submitted that the said expenditure was incurred for the welfare of the public at large and not for the benefit of any particular religious community, caste or sect. He further submitted that the Yagnas and Homams conducted by the assessee-trust were intended to promote wisdom, prosperity, health and environmental harmony and, therefore, cannot be regarded as activities undertaken for propagating any particular religion. The Ld. AR further submitted that providing financial assistance to deserving Vedic scholars and Veda Pathashalas is not a religious activity but an educational and charitable activity. In support of the above contention, reliance was placed on the decisions of the Bangalore Bench of the Tribunal in Sri Ashvalayana Vrunda v. ITO (ITA No.1084/Bang/2022, order dated 04.01.2023), Shri

- 4 - ITA No.2604/CHNY/2026 Maha Pidi Arisi Thittam Veda Rakshanam Trust Shruthiparampara Gurukulam v. ITO (ITA Nos.1082 & 1083/Bang/2023), Shrouta Vijnan Gurukulam v. ITO (ITA No.694/Bang/2024), Margdarshan Foundation v. DCIT (ITA Nos.768 & 769/Bang/2024) and the Panaji Bench decision in Prachya Viddya Samvardhan v. CIT (ITA No.146/Pan/2024), wherein it was held that providing financial assistance to Vedic scholars and institutions constitutes charitable activity and not a religious purpose, and accordingly approval u/s. 80G was directed to be granted. The Ld. AR further submitted that even the conduct of Yagnas cannot, by itself, be regarded as propagation of religion. In this regard, reliance was placed on the decision of the Ahmedabad Bench of the Tribunal in Dharamdas Charitable Trust v. CIT (Exemption) (ITA No.73/Ahd/2025, order dated 27.11.2025), wherein it was held that organizing Yagnas cannot be construed as a religious activity. Therefore, the Ld. AR submitted that the dominant objects and activities of the assessee-trust are charitable in nature and not religious. Hence, the order of the CIT(E) rejecting approval u/s. 80G deserves to be set aside and the CIT(E) may be directed to grant approval u/s. 80G of the Act.

4.

The Ld.DR relied on the order of the CIT(E).

- 5 - ITA No.2604/CHNY/2026 Maha Pidi Arisi Thittam Veda Rakshanam Trust 5. We have heard the rival submissions and perused the material available on record. We find that the CIT(E) rejected the assessee's application for approval u/s. 80G of the Act on the ground that the assessee is a religious-cum-charitable trust and that about 16% of its expenditure was incurred towards ritual and Vedic programmes. According to the CIT(E), since the expenditure incurred towards religious activities exceeded the prescribed limit, the assessee was not entitled to approval u/s. 80G of the Act. However, the specific contention of the assessee is that the dominant objects and activities of the trust are charitable in nature and that the expenditure incurred towards Vedic scholars, Veda Pathashalas, Yagnas and Homams is for the advancement of education, preservation of Indian heritage, public welfare and advancement of general public utility. It is further contended that such activities are intended to promote wisdom, prosperity, health and environmental harmony for the benefit of the public at large and are not confined to any particular religious community, caste or sect. The assessee has also relied upon a series of decisions of the Coordinate Benches of the Tribunal, wherein it has been held that providing financial assistance to Vedic scholars and Veda Pathashalas and organizing Yagnas, by themselves, do not constitute religious activities so as to disentitle a trust from approval u/s. 80G of the Act. On perusal of the impugned order, we find that

- 6 - ITA No.2604/CHNY/2026 Maha Pidi Arisi Thittam Veda Rakshanam Trust the CIT(E) has not examined the dominant purpose and the true nature of the activities carried on by the assessee-trust. The order proceeds mainly on the basis that a portion of the expenditure relates to Vedic programmes and rituals, without examining whether such activities are essentially charitable in nature or whether they are carried on for the benefit of the public at large. Further, there is no discussion in the impugned order with regard to the judicial precedents relied upon by the assessee on identical issues.

6.

In our considered opinion, while examining an application for approval u/s. 80G of the Act, the dominant objects of the trust and the real character of its activities are the relevant considerations. Mere description of the trust as a "religious-cum-charitable trust" or the fact that certain expenditure has been incurred towards Vedic programmes or Yagnas cannot, by itself, lead to the conclusion that the trust exists for religious purposes, without examining the purpose and manner in which such activities are undertaken. Therefore, in the interest of justice, we set aside the impugned order of the CIT(E) and restore the matter to his file with a direction to examine afresh the dominant objects and activities of the assessee-trust, keeping in view the judicial precedents relied upon by the assessee, and thereafter decide the application for approval u/s. 80G of the Act in accordance with law by

- 7 - ITA No.2604/CHNY/2026 Maha Pidi Arisi Thittam Veda Rakshanam Trust passing a speaking order after affording reasonable opportunity of being heard to the assessee. The assessee is directed to extend full co- operation and furnish all the documents and evidences as may be called for by the CIT(E). It is ordered accordingly.

7.

In the result, the appeal filed by the assessee is allowed for statistical purposes.

Order pronounced in the open court on 4th August, 2026 at Chennai.

Sd/- Sd/- (जॉज� जॉज� के) (इंटूर� रामा राव) (INTURI RAMA RAO) (GEORGE GEORGE K) लेखा सद�य/ACCOUNTANT MEMBER उपा�य� /VICE PRESIDENT चे�नई/Chennai, �दनांक/Dated, the 4th August, 2026 RSR, Sr.PS आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त /CIT, Chennai 4. �वभागीय ��त�न�ध/DR 5. गाड� फाईल/GF. By Order Digitally signed by REKHA REKHA SENTHIL RAJ SENTHIL RAJ Date: 2026.08.06 15:43:03 +05'30'

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