KACHCHI MOODOOR ARCHAKAS WELFARE TRUST,CHENNAI vs. CIT EXEMPTIONS, CHENNAI

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ITA 2612/CHNY/2026Status: DisposedITAT Chennai04 August 2026AY 2025-266 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(E) should have considered the principle of consistency and judicial precedents which treat financial assistance to Vedic scholars and Archakas as charitable. The matter was restored to the CIT(E) for fresh consideration.

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, holding that the trust's activities of propagating Vedas and Upanishads and assisting Archakas were religious in nature.

What were the issues?

Whether the activities of a trust promoting Vedic education and assisting Archakas are religious or charitable for the purpose of 80G approval, and the applicability of the principle of consistency.

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 26.03.2026, rejecting Form No.10AB filed for seeking approval u/s.80G of the Income Tax Act, 1961 (hereinafter the ‘Act’).

- 2 - ITA No.2612/CHNY/2026 Kachchi Moodoor Archakas Welfare 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 under section 80G of the Act. During the course of proceedings, the CIT(E) issued a show-cause notice stating that, on a perusal of the trust deed, the activities of the assessee-trust appeared to be religious-cum-charitable in nature. In response, the assessee explained the objects and activities of the trust, furnished the audited financial statements and other documents called for, and submitted that its activities were predominantly charitable in nature. However, the CIT(E) rejected the application for approval under section 80G of the Act on the ground that the trust was engaged in the propagation of Vedas and Upanishads, which, according to him, were essentially religious in nature, and therefore held that the assessee was not eligible for approval under section 80G of the Act.

3.

Aggrieved, assessee has filed the present appeal before the Tribunal. Aggrieved, the assessee has filed the present appeal before the Tribunal. Before us, the Ld. AR submitted that the assessee-trust had been enjoying approval under section 80G of the Act continuously from 01.04.1986 to 31.03.2026 and, in the absence of any material change in the objects or activities of the trust, the CIT(E) was not justified in taking a contrary view while considering the present application. In support of this contention, reliance was placed on the

- 3 - ITA No.2612/CHNY/2026 Kachchi Moodoor Archakas Welfare Trust decision of the Hon'ble Supreme Court in Radhasoami Satsang v. CIT reported in (1992) 193 ITR 321 (SC), wherein the principle of consistency was recognized. The Ld. AR further submitted that the CIT(E) erred in concluding that the objects of the trust are religious merely because the trust supports Archakas and promotes the study of Vedas and Upanishads. He submitted that the dominant object of the trust is charitable and not religious. The primary activities of the trust are to provide financial assistance to poor and deserving Archakas, who are Vedic scholars, thereby promoting education, preservation of Indian heritage and relief to the poor. None of the objects of the trust are confined to the propagation of any particular religion or meant exclusively for the benefit of any religious community. In this regard, reliance was placed on the decision of the Hon'ble Rajasthan High Court in Umaid Charitable Trust v. Union of India reported in (2008) 307 ITR 226, wherein it was held that the dominant object of the trust is the determinative test. The Ld. AR further submitted that the CIT(E) erred in treating financial assistance extended to Archakas and Vedic scholars as religious activity. He submitted that such assistance constitutes charitable activity in the nature of education and relief to the poor. 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 Shruthiparampara Gurukulam v. ITO (ITA Nos.1082

- 4 - ITA No.2612/CHNY/2026 Kachchi Moodoor Archakas Welfare Trust & 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 Veda Pathashalas constitutes charitable activity and not a religious purpose, and accordingly approval under section 80G of the Act was directed to be granted. 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 under section 80G of the Act deserves to be set aside and the CIT(E) may be directed to grant approval under section 80G of the Act.

4.

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

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 under section 80G of the Act on the ground that the trust is engaged in propagation of Vedas and Upanishads and in providing financial assistance to Archakas, which, according to the CIT(E), are religious activities disentitling the assessee from approval under section 80G of the Act. However, the specific contention of the assessee is that it had been enjoying approval under section 80G of

- 5 - ITA No.2612/CHNY/2026 Kachchi Moodoor Archakas Welfare Trust the Act continuously from 01.04.1986 to 31.03.2026 and that there has been no material change either in the objects or in the activities of the trust warranting a different view. It is also the case of the assessee that the dominant objects of the trust are charitable in nature and that financial assistance extended to poor and deserving Archakas, Vedic scholars and Veda Pathashalas constitutes charitable activity in the nature of education and relief to the poor and not religious activity.

6.

We find that the Hon'ble Supreme Court in Radhasoami Satsang v. CIT, supra has recognized the principle of consistency and held that, in the absence of any material change in facts or law, a view consistently accepted in earlier years should not ordinarily be departed from. We further find that the Coordinate Benches of the Tribunal in Sri Ashvalayana Vrunda v. ITO, supra and other connected decisions have consistently held that providing financial assistance to Vedic scholars, Archakas and Veda Pathashalas and promoting Vedic education, by themselves, do not render a trust as one established for religious purposes. Therefore, the CIT(E) ought to have examined the assessee's claim in the light of the above judicial precedents before rejecting the application. Accordingly, 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 consider the assessee's application afresh in the light of the above judicial precedents and in accordance with law after

- 6 - ITA No.2612/CHNY/2026 Kachchi Moodoor Archakas Welfare Trust affording a reasonable opportunity of being heard to the assessee. The assessee shall extend full co-operation and furnish all the requisite details 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 15:42:23 +05'30'

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