SHRI BAIR SINGH JI NARAYAN SINGH JI MEMORIAL SANSTHAN ,BIKANER vs. COMMISSIONER OF INCOME TAX (EXEMPTION), JAIPUR

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE- B, JAIPUR Jh fot; iky jko] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI VIJAY PAL RAO, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 910/JP/2018 cuke Shri Bair Singh Ji Narayan Singh Ji Commissioner of Income Vs. Memorial Sansthan, Bikaner Tax (Exemptions), Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AANTS3452R vihykFkhZ@Appellant izR;FkhZ@Respondent

fu/kZkfjrh dh vksj ls@ Assessee by : Shri Vinod Gupta (CA) jktLo dh vksj ls@ Revenue by : Shri V. S. Kothari (CIT) lquokbZ dh rkjh[k@ Date of Hearing : 03/12/2018 mn?kks"k.kk dh rkjh[k@Date of Pronouncement : 31/12/2018 vkns'k@ ORDER

PER: VIKRAM SINGH YADAV, A.M. This is an appeal filed by the assessee against the order of ld. CIT(E), Jaipur dated 31.05.2018 passed u/s 80G(5)(vi) of the Act. denying the approval u/s 80G of the Act.

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society and the income & expenditure account for the F.Y 2013-14, 2014-15 and 2015-16, the ld. CIT(E) has recorded a finding that the assessee society has incurred expenses of religious nature exceeding 5% of its total income and in view of the provisions of section 80G(5B), the assessee society does not qualify for approval u/s 80G of the Act. The relevant findings of the ld CIT(E) are contained at paras 4 and 5 of his order which are reproduced as under:

“4. While considering the approval u/s 80G the nature of activities under taken by the applicant sansthan is to be examined so as to ascertain the charitable character. On perusal of the Income & Expenditure account for the F.Y 2014-15, it is seen that the applicant sansthan has incurred Rs. 17,230/- on “Mandir Pooja Expenses” which is religious nature. This expenses is 5.73% of total receipts of Rs. 3,00,627/-. Thus expenses incurred on the religious activities by the assessee are more than 5% of the total receipts. 5. The attention is invited to the Section 80G(5B) of the I.T Act, 1961 which is reproduced as under:- “[(5B) Notwithstanding anything contained in clause (ii) of sub-section (5) and Explanation-3, an institution or fund which incurs expenditure, during any previous year, which is of a religious nature for an amount not exceeding five per cent of its total income in that previous year shall be deemed to be an institution or fund to which the provisions of this section apply].”

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The plain reading of section 80G(5) and 80G (5B) suggests that this section applies only to the charitable institution/fund. It also indicate that if the Institution/fund incurs expenses of religious nature not exceeding 5% of total income than also it will be eligible for approval u/s 80G. But if the expenses of religious nature exceed 5% of total income, the institution/fund cannot be granted approval.”

3.1 It was submitted by the ld AR that a perusal of the object of the Society shows that apart from other objects, Society has object of preservation and promotion of Temple, Dharmshala, Religious Places, Aashrams or historic buildings. Assessee Society incurred expenditure grouped under Mandir Pooja Expenses on old Mandir say approx 100

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years old situated at Jogalsar Village near Bikaner. That village is having population approx 6000. The building is having historical importance in the area. The building is visited by all locals irrespective of caste, creed or gender but only due to its historical importance. In the local area, said building is believed to be a place where people feel spiritual and seek mental enrichment. In such small places, it is a big temple building and common place of the village where people visits to get spiritual and mental enrichment irrespective of caste, creed or gender. The pooja is performed regularly by the locals at their expenses in the said temple. However, certain expenses which are also in part like: cleaning, maintenance, Prasad some time for distribution, agarbatti etc. have been contributed by the assessee society. The contributions have been made only to keep alive the interest of the locals in the said old heritage temple which is ancillary to the main object of the Assessee to preserve or promote such old temple building. Under the facts and circumstances, preservation and promotion of such buildings cannot be held as religious in nature.

3.2 It was submitted that the ld. CIT(E) has erred by not appreciating the fact that the temple under consideration is situated in a very small place and have spiritual importance for entire population of the area having historical importance as well as that area is not having such big building available for common assembly or performing common function of social importance at large. Merely on the basis of presentation in income & expenditure, a conclusion has been drawn by the ld CIT(E). It is important to note that assessee has used the temple accommodation for Training of Stitching to the local women from time to time. The

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relevant paper cuttings is also enclosed (PBP 25-33). The assessee is also running and maintaining a Tempo to collect garbage under “Swach Bharat Mission”. The relevant paper cutting is also enclosed (PBP 34- 37). The said Tempo is also parked in the temple premises. These show the temple premises are always available and used by the assessee to pursue its main object. It is obvious that under these circumstances, otherwise also, assessee society have certain obligations to temple management. Contribution made is insignificant in comparison to the regular benefit taken by the Society free of cost from the temple management for pursuing its main object. Therefore, ld CIT(E) failed to appreciate the substance and merely considered the form (presentation in the annual) without any enquiry or application of mind. In support, reliance was placed on the decision of ITAT Nagpur in case of Shiv Mandir Devsttan Panch Committee Sansthan Vs. CIT-1, Nagpur (ITA no. 223/Nagpur/2009 vide order dated 11.10.2012) wherein in para 12 of the order, it was held as under:

“12. Even we noted that all the building maintenance expenses. free food expenses and festival, prayer and daily expenses cannot be regarded to be the one incurred for religious object, even if the object is regarded to be religious one. It is not denied that in the building the assessee was carrying yoga centre, tailoring training centre as well as food for the needy and optical centre for the poor.”

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3.3 It was further submitted that even otherwise, Mandir pooja expenses are not religious in nature and reliance was placed on following case laws:

a. Hon’ble Rajasthan High Court in case of Umaid Charitable Trust Vs. The Union of India (order dated 02.05.2008) wherein it was held as under: “30. I have heard the learned Counsel for the parties at length and given my thoughtful consideration to the facts of the present case and the case laws cited at the Bar. 31. This Court is of the considered opinion that mere one contribution by the charitable trust to another trust which carried out repair and renovation of Lord Vishnu's Temple does not disentitle the petitioner - Trust from renewal of its exemption certificate under Section 80G of the Act. The line of distinction between religious purposes and charitable purposes is very thin and and no water tight compartment between the two activities can be very well established. Unless objective of the charitable trust in question itself is for spending its income for a particular religion and it is so found in the trust-deed, the Income Tax Department cannot reject the renewal of the Trust as Charitable Trust under Section 80G of the Act merely because one particular expenditure is for an activity which may be termed as spending for a particular religion. In the present case the repair and renovation of Lord Vishnu's temple does not necessarily mean that expenditure in question was for a particular religion only.

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b. Jaipur ITAT in case of Shri Radha Krishna Mandir Foundation Vs. CIT-II, Jaipur (ITA no. 814/JP/2012 dated 29.05.2013) has held as under:

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“2.4 ….Preserve ancient heritage Property & Temples in case of take over.

i) To do preserve of ancient property like fort, places, Heritage Property, Temple, etc.

ii) In case of takeover, the trust shall maintain the temple worship, puja, festivals according to the sampradaya in which the temple belong to.

iii) In case of the trust take over an existing temple of Vallabha Sampradaya the trust will work and maintain according to the Vallabha Sampradaya."

From bare reading of the above objects what we understand is that none of the objects are non-charitable or for the benefit of any individual or group of individual. Therefore, the objects (original as well as newly added) are charitable in nature.”

“2.8 The next objection of the ld. CIT is regarding maintenance of temple situated at Akshya Patra and Akshya Patra Foundation. The ld. CIT has raised the question that the assessee is not authorized by foundation to look after the management of the temple as no authorization letter has been produced by the assessee. It is pertinent to note that even if there is no written authorization produced by the assessee, the activity of maintenance and management of temple itself is a charitable in nature and therefore, non-production of authorization would not change the nature of the activities undertaken by the assessee. Thus the expenditure incurred by the assessee in relation to the

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activity of maintenance and management of temple would be the expenditure for charitable work.

2.9 The another objection raised by the ld. CIT is based on the report of the AO that as per the newly added objects, the assessee trust shall maintain the temple worship, pooja, festivals according to Sampradaya in which the temple belongs to. We do not find that such an activity of maintaining the temple as per rits and rituals of particular Sampradaya to which the temple belongs would amount the activity related to a particular religion or community. When the temples which are supposed to maintain by the assessee are open for general public then performing pooja or festivals in a particular manner does not change the public charitable nature of the activities to non-charitable. Even otherwise the objects of assessee trust do not specify the maintenance of any specific or particular temple belonging to a specific sampradaya and if a temple which is maintained by the assessee keeping in view all the rits and rituals being followed in the said temple as per particular sampradaya, the same would be irrelevant for the purpose of construing the objects as charitable.”

c. ITAT Nagpur in case of Shiv Mandir Devsttan Panch Committee Sansthan Vs. CIT-1, Nagpur (ITA no. 223/Nagpur/2009 dated 11.10.2012) has held as under:

“8. We have gone through the relevant clauses which have been regarded to be religious in nature by the CIT(A). The object clause of the trust reads as under:

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“Worship of Lord Shiva , Hanumanji, Goddess Durga and maintaining of temple. To celebrate festivals like Shivratri, Hanuman Jayanti, Ganesh Uttasav, Makar Sankranti, renovation and maintenance of temple. To make available temple for general public and to provide facilities for the public visiting temple. Balance fund, if any after utilizing for the above mentioned objects, may be utilized for education, social and the cultural activities. To conduct nursery school, library, sports club, hostels and other activities. To help poor children for education. To provide medical aid for poor. To help the peoples affected by natural calamity.”

Now the question arise whether these objects can be regarded to be of religious nature and the expenditure incurred for the fulfillment of these objects can be said to have been incurred for the benefit of particular religion.

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This clause stipulates that the Institution or the Trust must not be for the benefit of any particular religious community or caste. The words "religious community" means the group of people having a common religion or faith. The word "religion" means the belief in and worship to a superhuman controlling power, specially the personal god or gods, a particular system of faith and worship. It means the trust should not be for the benefit of any particular group of person having the common belief in worshiping of superhuman controlling power or having common system & faith and worship. If the trust is for the benefit of any particular community. It would include the advancement, support or propagation of a particular religion, worshipping of Lord shiva, hanumanji. Goddess. Durga and maintaining of temple temple, in our opinion, cannot be regarded for the advancement support or propagation of a particular religion. No evidence or material was placed on record or brought before us by the learned DR which may prove that these object relate to a particular religion. No doubt the DR argued that it relate to Hindu Religion but in our opinion it is not so, Lord shiva. Hanumanji, goddess Durga does not represent any particular religions, they are merely regarded to be the super power of the universe.

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purpose, it cannot be said that the assessee has not completed with the condition No. (iii) enumerated u/s. 80G(5) of the Act.

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may observe that Hinduism is a way of life of a civilized society. It as such is not a religion. In this regard we rely on the case of TT Kuppuswamy Chettair Vs. State of Tamil Nadu (1987) 100 L.W 1031 in which it was held "The word "Hindu"has not been defined in any of the texts nor in judgment made law. The word was given by British administrators to inhabitants of India, who were not Christians Muslims, Paris or Jewa. The alleged Hindu religion consists of four castes Brahmins, Kshatriyas, vaishyas and sudras belonging ultimately to two schools of law, mitasharas and dayabhaga. There is, however, no religion by the name Hindu'. It only shows that so called Hindu religion has been called for convenience." CIT must be aware of that the Hindu consists of a number of communities having the different gods who are being worshipped in a different manner, different rituals, different ethical codes. Even the worship of god is not essential for a person who has adopted Hinduism way of life. Thus Hinduism holds within its fold men of divergent views and traditions who have very little in common except a vague faith in what may be called the fundamentals of the Hinduism. The word 'community' means a society of people living in the same place. Under the same laws and regulations and who have common rights and privileges. This may apply to Christianity or Moslem but not to Hinduism. Therefore, it cannot be said that Hindu is a separate community or a separate religion. Technically Hindu is neither a religion nor a community. Therefore, expenses incurred for worshipping of Lord Shiva. Hanuman, Goddess Durga and for maintenance of temple cannot be regarded to be for religious

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purpose. Under these circumstances, we are of the view that the CIT is not correct in law in not allowing the approval to the assessee trust u/s. 80G of the Act. We accordingly, set aside the order of the CIT and direct the CIT to grant approval to the assessee-trust u/s. 80G(5)(vi) of the Act.”

d. ITAT Agra in case of Radha Raman Niwas Trust Vs. CIT-I, Agra (ITA no. 541& 542/Agra/2012 dated 22.03.2013) has given decision in favour of assessee by relying on above referred judgement judgement of Hon’ble ITAT Nagpur in case of Shiv Mandir Devsttan Panch ommittee Sansthan.

e. Hon’ble Gujarat High Court in case of Hiralal Bhagwati vs. Commissioner of Income-Tax (2000) 246 ITR 188 has held that: “30. In the result, we allow this petition and we quash and set aside an order rejecting the application for exemption under s. 80G(5) of the Act, with a direction to decide the same in accordance with law. The proceedings initiated under s. 148 of the IT Act against the assessee for the asst. yr. 1984-85, and the notices issued under ss. 271(1)(a), 271(i)(c) and 273(2)(b) for the asst. yr. 1985-86 are hereby quashed and set aside. Rule is made absolute to the aforesaid extent.”

3.4 It was further submitted that the ld. CIT(E) has merely proceeded in mechanical manner to derive conclusion and rejected the application by holding that in one of the three financial years i.e. F.Y 2014-15, Mandir Pooja Expenses is 5.73% of the total receipts which is in excess of 5% to the total receipts. It was submitted that the ld. CIT(E) has

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taken the Mandir Pooja Expenses from the face of the Income & Expenditure Account without going into the actual nature of expenditure debited in said Ledger.

3.5 It was further submitted that even for calculation of percentage of Mandir Pooja Expenses, ld. CIT(E) used total receipts, whereas, the relevant Section used the word “Total Income”. In that case, Assessee have received voluntary contribution and bank interest, does not have any business income, income from house property or any other source of income. The term “Total Income” has also not defined. It is trite law that the interpretation of term should be according to purpose and context in which, it has been used. Perusal of the Section shows that it is the intention to allow religious nature to be considered as charitable purpose but with certain limitations i.e. 5%. Under the circumstances, all income should be clubbed otherwise; it may take to irrational conclusion. In the instant case, apart from voluntary contribution and bank interest, there is accommodated income as well. Ld. CIT(E) has not included that accumulated income i.e. Rs. 87,212/-. After including that amount, the total income comes to Rs. 3,87,839/- and percentage of Mandir Pooja Expenses comes to 4.44%.

3.6 It was alternatively submitted that section 80G is related to deduction in respect of donation while computing the total income of the Assessee. It is relevant to note that income of assessee has to compute every year and every year is separate from each other. Section 80G(2)(iv) says donation to any other fund or institution to which this section applies. Section 80G(5) is about to which fund or institution

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referred in Section 80G(2)(iv), it will apply. Perusal of all above Sections in meaningful manner, it is clear that it is annual exercise while computing the income of any Assessee to find out whether given to particular institute or fund is eligible for deduction under Section 80G or not. Section 80G(5B) is also states certain criteria to determine whether Section 80G apply or not. For ready reference, we produced the same as follows:-

“(5B) Notwithstanding anything contained in clause (ii) of sub- section (5) and Explanation 3, an institution or fund which incurs expenditure, during any previous year, which is of a religious nature for an amount not exceeding five per cent of its total income in that previous year shall be deemed to be an institution or fund to which the provisions of this section apply.”

In view of forgoing discussions of law, it is clear that on year to year basis, it have to see that whether a particular trust or fund have incurred expenditure more than 5% of religious nature. Filing of application and examination by CIT(E) is a procedural part and can not over ride the legal provision. In the instant case, the finding of the CIT(E) of non applicability is only with respect to F.Y. 2014-15 and same can not be apply to other years.

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the assessee society cannot be allowed registration under section 80G of the Act. It was further submitted that while granting the approval, the ld CIT(E) has to call for and examine the financial statements of last three years and in the instant case, on such examination, the ld CIT(E) has found that in the financial year, pooja expenses as per assessee’s own Income and Expenditure account exceeds 5% of total income for the financial year 2014-15, the provisions of section 80G(5B) are clearly attracted. He accordingly relied on the order of the ld CIT(E) and submitted that the assessee society has been rightly denied the registration under section 80G and the order of the ld CIT(E) may therefore be confirmed.

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context of Section 80G(5), in absence of any adverse finding, the assessee society has also been found fully compliant with the conditions specified u/s 80G(ii) and 80G(iii) as well as Explanation 3 to section 80G of the Act. In other words, the assessee society is registered as a charitable society, none of its objects provide for transfer or application of whole or any part of the income for any purpose other than charitable purpose, it is not for the benefit of any particular religious community or caste and none of its objects include any object the whole or substantially the whole of which is religious in nature.

“(5B) Notwithstanding anything contained in clause (ii) of sub- section (5) and Explanation 3, an institution or fund which incurs expenditure, during any previous year, which is of a religious nature for an amount not exceeding five per cent of its total income in that previous year shall be deemed to be an institution or fund to which the provisions of this section apply.”

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33.2 In order to mitigate hardship to such funds or institutions, the provisions of section 80G are amended so as to provide that in case such institutions or funds spend upto five per cent of their

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income during the relevant previous year for religious purpose, the benefit of deduction will not be denied to them.

33.3 This amendment will take effect from the 1st day of April, 2000 and will, accordingly, apply in relation to assessment year 2000-2001 and subsequent years.”

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should not be read as an additional and an independent condition which a fund or institution has to comply with in order to seek registration under section 80G of the Act. In the instant case, it is not the case of the Revenue that the assessee society is governed by section 80G(5)(ii) and has in its instrument/object any provision for the transfer or application of the whole or any part of the income or asset for any purpose other than a charitable purpose. It is also not the case of the Revenue that it is for the benefit of any particular religious community or caste and any of its objects include any object the whole or substantially the whole of which is religious in nature. In view of the same, the provisions of section 80G(5B) cannot be invoked in the instant case and the order of the ld CIT(E) deserve to be set-aside on this ground itself.

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compartment between the two activities can be very established. In the facts of the present case, we donot believe that where the assessee has incurred certain expenses for upkeep and maintenance of the temple premises and distribution of prasad to public at large, it would be an activity related to a particular religion or community and the expenses so incurred would be in nature of religious expenses. In case of Umaid Charitable Trust (supra), the Hon’ble Rajasthan High Court has held that unless objective of the assessee society is for spending its income for a particular religion and it is so found in the trust deed, the Revenue cannot reject the application seeking registration under section 80G merely because the assessee has incurred certain expenses for upkeep and maintenance of the temple premises and distribution of prasad to public at large. Similarly, the Coordinate Bench in case of Shri Radha Krishna Mandir Foundation (supra) has held as under:

“2.9 The another objection raised by the ld. CIT is based on the report of the AO that as per the newly added objects, the assessee trust shall maintain the temple worship, pooja, festivals according to Sampradaya in which the temple belongs to. We do not find that such an activity of maintaining the temple as per rits and rituals of particular Sampradaya to which the temple belongs would amount the activity related to a particular religion or community. When the temples which are supposed to maintain by the assessee are open for general public then performing pooja or festivals in a particular manner does not change the public charitable nature of the activities to non-charitable. Even otherwise the objects of assessee trust do not specify the maintenance of any specific or particular temple belonging to a specific sampradaya and if a temple

24 ITA No. 910/JP/2018 Shri Bair Singh Ji Narayan Singh Ji Memorial Sansthan, Bikaner Vs. CIT(E), Jaipur which is maintained by the assessee keeping in view all the rits and rituals being followed in the said temple as per particular sampradaya, the same would be irrelevant for the purpose of construing the objects as charitable.”

In the result, the appeal of the assessee is allowed.

Order pronounced in the Open Court on 31/12/2018.

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