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

ITA 1287/CHNY/2025Status: DisposedITAT Chennai09 March 202620 pages
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What did the Tribunal hold?

The Tribunal held that the assessee's educational activities were systematic and qualified as charitable. It also found that charging nominal fees for upkeep does not negate the charitable nature of education, and the trust's surplus is reinvested. The Tribunal noted that while 'relief of the poor' and 'medical relief' activities were yet to commence, the primary object of education was being pursued.

What were the facts?

The assessee, a public charitable trust with objects including promotion of Sanskrit, education, and public health, applied for regular registration under Section 12AB and approval under Section 80G. The CIT(E) rejected these applications, citing unorganized Vedic/Sanskrit courses, engaging in business activities by collecting fees, and lack of activities for 'relief of the poor' and 'medical relief'.

What were the issues?

Whether the assessee's educational activities, including fee collection, qualify as charitable under the Income Tax Act, and whether the rejection of registration and approval was justified based on the grounds cited by the CIT(E).

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii),Section 12AB,Section 80G,Section 2(15)

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Income Tax Appellate Tribunal, A BENCH: CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRIS.R.RAGHUNATHA

For Appellant: Mr. Y Sridhar, FCA
For Respondent: Ms. E. Pavuna Sundari, CIT
Hearing: 13.01.2026Pronounced: 09.03.2026

PER MANU KUMAR GIRI, Judicial Member:

The captioned appeals are directed against the orders both dated 21.03.2025 passed by the Ld. Commissioner of Income Tax (Exemptions), Chennai [“CIT(E)”] rejecting the application filed by the assessee in Form No. 10AB u/s. 12A(1)(ac)(iii) seeking regular registration u/s. 12AB and application filed in Form No.10AB seeking approval u/s.80G of the Income Tax Act, 1961 (“t

The order continues below.

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