VYASA VIDYA MANDIRAM,COIMBATORE vs. CIT, EXEMPTIIONS,, CHENNAI

Before us ld. AR filed written submissions as under: APPEAL AGAINST ORDER OF REJECTION FOR REGISTRATION U/S 12AB(1) r.w.s.12A(1)(ac) (iii) OF THE INCOME-TAX AСТ, 1961 Written Submission

The appellant (assessee) was constituted by a Trust Deed dated 11.02.2022 with the following objects:

The appellant commenced its charitable activities from the FY 2021-22 (AY 2022-23) itself. Income and Expenditure account and Balance Sheet pertaining to the FY 2021-22 are enclosed along with financials for the FYs 2022-23 and 2023-24, to demonstrate commencement of the Trust's charitable activities.

The appellant got itself provisionally registered u/s.12A(1)(ac) (vi) of the Income-Tax Act, 1961 (Act) on 06.03.2023 which pertains to the AYs 2023-24 to 2025-26. The appellant Trust also got itself provisionally approved under clause (iv) of first proviso to section 80G(5) of the Act on the same day (06.03.2023). The provisional approval u/s 80G of the Act was granted to the assessee from 06.03.2023 to AY 2025-26.

The appellant applied for regular registration u/s 12A(1)(ac) (iii) of the Act, vide application in Form No.10AB on 12.09.2024. This application for registration was rejected by the Ld. Commissioner of Income-Tax (Exemptions), Chennai [CIT(E)], in order dated 21.03.2025. The main reasons for rejection are enlisted below:

On the first ground of rejection, it may be noted that the Ld. CIT(E) failed to note that the assessee Trust is conducting its courses with regular classes, a fixed curriculum, attendance criteria and evaluation through examinations for different set of courses. It also provides grading to the students based on the exams conducted, with below a certain grading being considered as 'failed', requiring the concerned student to write the exam again. 5.1. It may be, thus, seen that the assessee Trust is run like any systematic school of education and it has satisfied the requirements laid down in Loka Shikshana Trust, inasmuch as it is imparting scholastic learning in a formal and systematic manner and hence, it is to be regarding as a Trust engaged in providing education. In this regard, reliance is also placed on the Delhi High Court judgement in the cases of Delhi Music Society v. DGIT (17 taxmann.com 49), CIT v. NIIT Foundation (164 taxmann.com 628) and on the Chennai ITAT decision in the case of Smt. Lingammal Ramaraju Shastra Prathistha Trust v. ACIT(E) (168 taxmann.com 476). Further, the main question before the Apex Court in the case of New Noble was the correct meaning of the term "solely" in the context of educational institutions seeking exemption section 10(23C) (vi) of the Act. Thus, the decision of the Supreme Court (in the case of New Noble) which was in the context of section 10(23C) (vi) of the Act cannot be applied to cases involving exemption u/s 11 and 12 of the Act.

As regards the second ground of rejection, it may be noted that the assessee Trust is only charging nominal fees from students and that too, for the upkeep of the educational institute under the aegis of the assessee Trust. It may be noted that even an educational institute has to have employees, has to print educational material for consumption of its students, etc., and all this has a cost. Moreover, it may be noted that for the 'charitable purpose' contemplated in section 2(15) of the Act, eleemosynary need not always be adhered to. For example, charging of school fees from children when an educational institution is run for imparting of education will not alter the character of charitable purpose of education. Thus, eleemosynary which in the true sense conveys the ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai :: 5 ::

On the third ground of rejection, it may be noted that though the assessee Trust has 'medical relief and 'relief of the poor' as its objects, it is yet to indulge in these activities. This may be viewed in the background of the fact that the Trust came into being only in 2022 and it may undertake those activities in the near future. In any case, the assessee Trust is engaged in the activity of 'education', presently, which is also an object mentioned in the Trust Deed. It may also be noted that carrying on all the objects mentioned in the Trust Deed is not necessary to establish genuineness of a Trust.

Thus, it may be seen that none of the reasons stated by the Ld. CIT(E) for rejection of assessee's application for registration u/s 12AB of the Act is tenable.

In the light of the above, it is prayed that the ld. CIT(E) may be directed to consider the assessee's application for grant of registration u/s 12AB of the Act

In the substance the Ld. Authorised Representative (ld.AR) has summarized his arguments submitting that the trust conducts regular classes. There is a fixed curriculum. Attendance criteria are prescribed. Examinations are conducted. Grading system is followed and students below prescribed grading are required to reappear. Thus, the trust imparts systematic scholastic instruction and satisfies the test laid down in Lok Shikshana Trust (supra). He placed reliance on Delhi Music Society v. DGIT, CIT v. NIIT Foundation and Smt. Lingammal Ramaraju Shastra Prathistha Trust v. ACIT(E). It was further submitted that the decision in New Noble Educational Society ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai :: 6 ::

With regard to “medical relief” and “relief of the poor”, it was submitted the trust was constituted only in 2022. It is presently engaged in education, which is one of its main objects. It is not necessary that all objects must be simultaneously carried out to establish genuineness. Therefore, he prayed that both the rejections be set aside and registration u/s. 12AB and 80G approval be granted.

The Ld. Departmental Representative (ld.DR) Ms. E. Pavuna Sundari, CIT supported the order of the ld.CIT(E) and reiterated fees collected constitute commercial receipts. Courses are unrecognized. Activities do not strictly fall within formal schooling. Hence, she pleaded that registration was rightly denied.

We have carefully considered the rival submissions and material on record. We have to see what is the scope of Registration u/s. 12AB. At the stage of granting registration, the authority is required to examine: 1. The objects of the trust; and 2. The genuineness of its activities.

We further note that the ld.CIT(E) relied heavily on Lok Shikshana Trust (supra). However, in the present case the assessee conducts structured courses with defined duration. There is curriculum, examination and grading. Instruction is systematic and organized. These features clearly satisfy the test of systematic scholastic instruction as laid down by the Supreme Court. The decisions in Delhi Music Society v. DGIT and CIT v. NIIT Foundation support the proposition that organized and structured instruction constitutes education even if not affiliated to a University. The reliance placed by the CIT(E) on New Noble Educational Society (supra) is misplaced inasmuch as the context there was section 10(23C). Registration u/s. 12AB stands on a different statutory footing.

The mere charging of fees does not ipso facto render the activity commercial. As held in ‘In Re Trustees of the Tribune, In Re Trustees of the Tribune [1939](7 ITR 415)(PC)’ charity need not provide something for nothing. There is no finding that surplus is distributed, or that trustees derive personal benefit, or that profit motive is dominant. The dominant object remains education. Incidental surplus does not convert a charitable activity into business.

Furthermore, trust is recently constituted. It is well settled that at the registration stage, actual execution of every object is not mandatory. So long as objects are charitable and activities are genuine, registration cannot be denied. Education being one of the core objects, and the trust actively engaged in that activity, the requirement stands satisfied.

In a akin situation Banglore Bench of Tribunal in dated 21.05.2024, after considering below objects held as under:

The word `Veda’ means `knowledge’ and is derived from the Sanskrit word `vid’, which means `to know’. The word `Veda’ signifies highest sacred, eternal and divine knowledge as well as the texts embodying that knowledge. The significance of the Veda is manifold. It has been universally acknowledged ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai :: 9 ::

After the formation of the Trust, the assessee conducted various workshop to disseminate the knowledge of Vedas. General public irrespective of caste, creed, gender or "religion were invited to witness the said events and to know the significance and importance of Vedas. The Vedic Scholars were identified and felicitated irrespective of their caste, creed or religion. The assessee-trust has given financial assistance to various people, irrespective of caste, creed or religion, involved in Indian Heritage Education. Trust conducts teaching of Vedas by various scholars to students, working people, retired persons etc. irrespective of caste, creed, religion. The trust has conducted the vedic classes by going to the houses of all interested people irrespective of caste, creed, gender or religion and has taught them the importance of Vedas. During Covid, the trust provided financial assistance to the poor Vedic scholars and distributed food kit, cloths, medicines for the needy. All the expenses to carry out the above charitable objectives are met out of donations received. No fees or honorarium or money is charged by the trust or by any Trustees for conducting the vedic classes, chanting or for any programmes. All trustees work selflessly for achieving the charitable objects of the Trust.

The approval by the PCIT u/s. 80G requires fulfilment of all the conditions laid down in clauses (i) to (v) of section 80G(5). The conditions are as under:- (i) The income of the Trust is not liable to inclusion in its total income u/s. 11, 12, 10(23AA), 10(23C) as the case may be. (ii) The instrument under which the institution or fund is constituted does not, or the rules governing the institution or fund do not, contain any provision for the transfer or application at any time of the whole or any part of the income or assets of the institution or fund for any purpose other than a charitable purpose; (iii) the institution or fund is not expressed to be for the benefit of any particular religious community or caste; (iv) the institution or fund maintains regular accounts of its receipts and expenditure; ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai :: 10 ::

Explanation 3 to section 80G states that "charitable purpose" does not include any purpose the whole or substantially the whole of hich is of a religious nature. In the present case, the learned CIT(E) has held that the assessee is engaged in a religious activity of teaching Vedas, a Hindu religious scripture, to Hindu students and hence the whole purpose of the trust is of religious nature as per Explanation 3 to section 80G. It is therefore concluded that the assessee Trust is not eligible for approval u/s. 80G. In coming to the above conclusion, the learned CIT(E) has relied on certain judicial pronouncement, which we shall deal later.

It is settled principle that Hinduism is a way of life and not a religion. The Hon’ble Madras High Court in TT Kuppuswamy Chettiar and others v State of Tamil Nadu (1987) 100 LW 1031 held as under:-

The Constitution Bench of the Supreme Court in Dr Ramesh Yeshwant Prabhoo v Shri Prabhakar Kashinath Kunte and Others 1996 AIR 1113 referring to various constitution bench decisions, Encyclopedia of Religion and Ethics, Dictionaries, Encyclopaedia Britannica and Treatise, had held as under. “These Constitution Bench decisions, after a detailed discussion, indicate that no precise meaning can be ascribed to the terms `Hindu', `Hindutva' and `Hinduism'; and no meaning in the abstract can confine it to the narrow limits of religion alone, excluding the content of Indian culture and heritage. It is also indicated that the term `Hindutva' is related more to the way of life of the people in the sub- continent. It is difficult to appreciate how in the face of these decisions the term `Hindutva' or `Hinduism' per se, in the abstract, can be assumed to mean and be equated with narrow fundamentalist Hindu religious bigotry, or be construed to fall within the prohibition in sub-sections (3) and/or (3A) of Section 123 of the R.P. Act.” Ordinarily, Hindutva is understood as a way of life or a state of mind and it is not to be equated with, or understood as religious Hindu fundamentalism. “Thus, it cannot be doubted, particularly in view of the Constitution Bench decisions of this Court that the words `Hinduism' or `Hindutva' are not necessarily to be understood and construed narrowly, confined only to the strict Hindu religious practices unrelated to the culture and ethos of the people of India, depicting the way of life of the Indian people. Unless the context of a speech indicates a contrary meaning or use, in the abstract these terms are indicative more of a way of life of the Indian people and are not confined merely to describe persons practising the Hindu religion as a faith. Considering the terms `Hinduism' or `Hindutva' per se asdepicting hostility, enmity or intolerance towards other religious faiths or professing communalism, proceeds form an improper appreciation and perception of the true meaning of these expressions emerging from the detailed discussion in earlier authorities of this Court.”

The Hon’ble Allahabad High Court in CIT v Sri Radha Raman Niwas Trust [2014] 42 taxmann.com 77 affirmed the findings of the Tribunal, which held that to carry sewa puja of Sri Giridhari Ji and carry Akhand Naam Sankirtan uninterruptedly in Aashram is one type of meditation and yoga and is a charitable activity u/s. 2(15) of the I.T.Act. The High Court held that unless it was proved that the above activities was for any particular community or group of persons, it cannot be a ground to reject the registration u/s 12A and approval u/s 80G of the I.T.Act.

The Tribunal in Shiv Mandir Devsttan Panch Committee Sanstan v CIT [2012] 27 taxmann.com 100 (Nagpur Trib) referring to the above decisions held that worship of Lord Shiva, Hanumanji, Goddess Durga and maintaining of temple cannot be regarded as for the advancement support or propagation of a particular religion and granted the approval u/s. 80G of the I.T.Act. The relevant observations from the decision are as under:-

In the case of Commissioner of Hindu Religious and Charitable Endowments Madras v. Sri Lakshmindra Thirtha Swamiar 1954 SCJ 335, Religion has been expressed to mean a matter of faith with individuals or communities and it is not necessarily theristic. There are well known religions in India, like Buddhism and Jainism, which do not believe in God or in any intelligent first cause. A religion undoubtedly has its basis in a system of beliefs or doctrines which are regarded by those who profess that religion as conducive to their spiritual well being, but it will not be correct to say that religions is nothing else but a doctrine or belief. A religion may not only lay down a code of ethical rules for its followers to accept, but it might prescribed rituals and observances, ceremonies and modes of worship which are regarded as integral parts of a religion, and these forms and observances might extend even to matters of food and dress. No material or evidence has been brought on record by the department which may prove that any person coming, worshipping and maintaining the temple has to follow a particular code of ethical rules and has to carry out the prescribed rituals and observances, ceremonies and modes of worship. The entry is not restricted to a particular group of persons. Any body whether want to worship or not and want to maintain or not can come to the temple and avail of all the facilities available to the public at large. Therefore, these objects cannot be regarded to be the religious objects. In our opinion, until and unless the activities for which the trust is established, involve the activity religious purpose, it cannot be said that the assessee has not complied with the condition No. (iii) enumerated u/s. 80G(5) of the Act.

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.

Explanation 3 to section 80G(v) states that "in this section, "charitable purpose" does not include any purpose the whole or substantially the whole of which is of a religious nature." This explanation takes note of the fact that an institution or fund shall be for a charitable purpose and may have a number of objects. If any one of these objects is wholly or substantially wholly of a religious nature, the Institution or Funds falls outside the scope of ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai :: 13 ::

The ITAT Bangalore bench in M/s Sri Channamallikarjuna Trust Committee Gangavathi v CIT (E) – (order dated 4.5.2022) explained the difference between charitable purpose and religious purpose and held as under:-

We are of the view that the objects and purposes of the Assessee are both charitable and religious, the Assessee does not exist exclusively for the benefit of a particular religious community. The objects do not channel the benefits to any community and thus, would not fall as an institution existing solely for religious purpose. In that view of the matter, we are of the view that the Assessee is a charitable and religious trust which does not benefit any specific religious community and therefore, it cannot be held that it exists solely for religious purpose. It cannot be characterised as religious object Page 15 of 22 especially when it does not make a distinction between caste, creed, race, religion, etc.

In the light of the aforesaid discussion, we are satisfied that the plea of the Assessee to recognize it as existing for “Charitable Purpose” deserves to be accepted and is accepted. We accordingly allow the plea of the Assessee and direct that the registration be allowed treating the Assessee as existing for “Charitable purpose”.

In Vaidik Bhakti Sadan Asram v CIT [2010] 5 ITR (Trib) 590 (Delhi), the Tribunal held that propagation of vedic thoughts and philosophy cannot be attributed to any religion as the same are more concerned with the lifestyle of the human beings. The relevant observations are as under:- “9. A perusal of the impugned order of the learned Commissioner of Income-tax shows that the renewal of registration u/s. 80G was denied by him to the assessee-trust mainly on three grounds which have already been enumerated by us while narrating the facts of the case in the foregoing portion of this order. At the time, of hearing before us, learned counsel for the assessee has made elaborate submissions to meet all these objections raised by the learned Commissioner of Income-tax while denying exemption to the assessee u/s. 80G. As ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai :: 15 ::

In view of the above judicial pronouncements of the Hon’ble Supreme Court, Hon’ble High Court and various Tribunal (including the Bangalore bench), there is no merit in the impugned finding of the CIT(E) that teaching Vedas is a religious activity and therefore not eligible for approval u/s. 80G of the I.T.Act.

As regards the case law relied on by the CIT(E), we find that in the case of Upper Ganges Sugar Mills Ltd v CIT (supra), one of the objects of the Trust deed was ‘to establish, maintain and to grant and / or aid to public places of worship and prayer halls’. The Hon’ble Apex Court considering the said object, held as under:- “10. To reiterate, 'Explanation 3 does not require the ascertainment of whether the whole or substantially the whole of the institution or fund's charitable purpose is of a religious nature. If it did, it would read differently. It requires the ascertainment of whether there is one purpose within the institution or fund's overall charitable purpose which is wholly, or substantially wholly, of a religious nature. There is little doubt that clause 2(h)of the trust deed which permits the trustees to support prayer halls and places of worship sets out a purpose the whole or substantially the whole of which is of a religious nature, and this has not been seriously disputed. Therefore, in our view, the Trust and the donation by the assessee to it fall outside the scope of section 80G.”

In the present case, objects of the assessee-Trust are reproduced at para 6 (supra) and they are available at page 31 to 33 of the paper book filed by the assessee. The assessee Trust does not have any object ‘to establish, maintain and to grant and / or aid to public places of worship and prayer halls’ and hence the judgment of the Hon’ble Apex Court in the case of Upper Ganges Sugar Mills Ltd. v. CIT (supra) is inapplicable to the facts of the present case. The impugned conclusion of the learned CIT(E) that teaching of Vedasinvolve offering worship and prayer to God is not correct and bereft of any reason. The assessee only teaches the students how to recite the Vedas. There is a particular method of pronunciation of Vedas with Swaras attached to it. The recitation and pronunciation of Vedas is what is taught by the assessee-Trust.

The ITAT Jaipur in Shiv Ratan Rathi Foundation v CIT [2012] 20 taxmann.com 221 (JP) followed the decision of the Supreme Court in Upper Ganges and held that organising ‘Bhagavat Katha’ is a religious activity and therefore Trust would not be granted the approval u/s. 80G. In the present case as explained above, the Supreme Court decision in Upper Ganges is not applicable and also the assessee-Trust does not have any object of organising ‘Bhagavat Katha’. It is only teaching how to pronounce and recite the Vedas, a Sanskrit literature. Thus, the above decision is not applicable to the present case.

The Hon’ble High Court of Rajasthan in Umaid Charitable Trust v UOI (supra) distinguished the judgment of the Hon’ble Supreme Court in Upper Ganges and held as under:- “33. The learned counsel for the revenue relied upon the decision of the Supreme Court in the case of Upper Ganges Sugar Mills (supra), which has been relied upon by the learned CIT(A) also in the impugned order, it was held on the basis of one particular clause (2)(h) of the trust-deed which read "to establish, maintain and to grant and/or aid to public places of worship and prayer halls". The Hon'ble Supreme Court dealing with Explanation4 of section 80G(5) held as under : "To reiterate, Explanation 3 does not require the ascertainment of whether the whole or substantially the whole of the institution or fund's charitable purpose is of religious nature. If it did, it would read differently. It requires the ascertainment of whether there is one purpose within the institution or fund's overall charitable purpose which is wholly, or substantially wholly, of a religious nature. There is little doubt that clause 2(h) of the trust deed which permits the trustees to support prayer halls and places of worship sets out a purpose the whole or substantially the whole of which is of religious nature, and this has not been seriously disputed. Therefore, in our view, the trust and the donation by the assessee to it fall outside the scope of section 80G." (p. 582)

In the above judgment, it was held by the Hon’ble Rajasthan High Court that approval u/s. 80G cannot be refused if one particular expenditure was made for repair and renovation of Lord Vishnu’s temple and that too by way of contribution to another trust. Relevant observations are as under:-

The CIT(E) has relied on Kasyapa Veda Research Foundation v CIT [2011] 12 taxmann.com 286 (Cochin) to hold that Vedas are religious scriptures and Vedic Study is a study of Hindu religion or religious instruction. The said decision is distinguishable in view of various decisions as discussed hereinabove which holds that Hinduism itself is not a religion or community. The constitution bench decisions of the Supreme Court were not brought on record in the above decision and hence it is distinguishable. Without prejudice, the Tribunal in the above decision noted that universal appeal of Vedas and allowed registration in the status of charitable and religious Trust by holding as under:- “Vedas: Universal appeal 4.6 Vedanta is the philosophy which analysed and taught man to be moral consciously. It is the essence of all religions. The Hindu scriptures teach that man is attracted to this earth to learn, more completely in each successive life, the infinite ways in which the Spirit may be expressed through, and be dominant over, material conditions. Slowly but surely, man, throughout the world, including India, across different religions, nationalities and ideologies, with the entering of the atomic age and the expansion of the world mind, is learning these truths. Wisdom garnered by India, the eldest brother among the nations, is a heritage of all mankind. Vedic truth, as all truth, belongs to the Lord and not to India. The Rishis, whose minds were pure receptacles to receive the divine profundities of the Vedas, were members of the human race, born on this earth to serve humanity as a whole. Distinction by race or nation is meaningless in the realm of truth, where the only qualification is spiritual fitness to receive. The time tested scriptures of the world are one in essence.” “Some overlap between the 'religious' and the 'charitable' is inherent in the very definitions of the two concepts, and has to be admitted and respected. Continuing further, we also observe that the activities of the trust are not confined to these activities alone, but is also undertaking purely charitable activities. As apparent from the Object Clause 2(c), (d), (f ), (i), (j) and (k ) of its Trust Deed, as well as the activities undertaken in pursuance of the same, as listed in the 'Note on its activities' (refer PB pgs. 8,9 and 10). In our considered view, therefore, the appellant-trust qualifies to be a charitable trust as well. Accordingly, it is to be allowed the status of a religious and charitable trust.

Moreover, the assessee-trust has carried on other charitable activities in the nature of relief of poor. The Vedic Scholars were identified and felicitated irrespective of their caste, creed or religion. The Trust has given financial assistance to various people, irrespective of caste, creed or religion, involved in Indian Heritage Education. During Covid, many were in financial difficulty and the Trust provided financial assistance and distributed food kit, clothes, medicines for the needy Vedic scholars irrespective of their caste, religion or gender. All the expenses were met out of voluntary contributions or donations. The Income and expenditure account for AY 2021-22 are placed on record at page 86, 87 of paper book], and for AY 2022-23, ledger account for expenses incurred in achieving the objects like donation to veda pathashalas, veda pundits, medical assistance etc [Page 94 to 99 of paper book] and invoices, ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai :: 19 :: vouchers, brochures and photos [page 127 to 157 of paper book] demonstrates the charitable activities carried on by the assessee Trust. Thus the activities carried on by the assesseeTrust are CHARITABLE in the nature of education, relief of poor and not RELIGIOUS as concluded by the CIT(E). In view of the above, the impugned findings of the CIT(E) that the assessee-trust is registered as RELIGIOUS is quashed and the assessee is allowed registration u/s 12A of the I.T.Act as charitable trust. Consequently, the approval u/s 80G of the I.T.Act is to be granted. It is ordered accordingly.

In the result, the appeals filed by the assessee-trust are allowed.”

A similar view has also been held in the case of Shrthiparampara Gurukulam Vs. ITO (supra). In view of the aforesaid Orders of the Bangalore Bench of the Tribunal which has considered judicial precedence on the subject, we hold that propagation of vedic thoughts and philosophy cannot be attributed to any religion as same are more concerned with the life style of the human beings. Therefore, we hold that the activities carried on by the assessee trust is charitable in nature and not religious, hence, would be entitled to the grant of approval u/s. 80G of the Act. It is ordered accordingly.

In light of the above factual matrix and respectfully following the order of Banglore bench of Tribunal (supra) we find that the objects of the trust are charitable in nature. The activities of conducting structured Sanskrit courses amount to “education” within section 2(15). Charging nominal fees does not negate charitable character. Non-commencement of certain objects is not fatal at registration stage. The ld.CIT(E) erred in law and on facts in rejecting the application. Accordingly, the impugned orders dated 21.03.2025 are set aside. The Ld. CIT(E) is directed to grant registration to the assessee u/s. 12AB and approval u/s.80G of the Act.

In the result, both the appeals of the assessee are allowed. Order pronounced on the day of 09th March 2026, in Chennai.

अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF