SHREEJI EDUCATION AND CHARITABLE TRUST,JAM KANDORANA vs. ITO EXEMPTION WD 1, RAJKOT, RAJKOT

ITA 107/RJT/2025Status: DisposedITAT Rajkot21 July 2025AY 2025-26Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the trust's objects, while including some religious aspects, did not exclusively benefit a particular religious community and were not substantially or wholly religious in nature. Therefore, the trust satisfied the conditions for charitable purposes under Section 80G.

What were the facts?

The assessee, Shreeji Education and Charitable Trust, applied for approval under Section 80G(5)(iii) of the Income-tax Act. The CIT(E) rejected the application, finding that some objects in the trust deed were religious in nature, thus violating the condition that the trust must be solely for charitable purposes.

What were the issues?

Whether the trust's objects, which included religious aspects, disqualified it from obtaining approval under Section 80G as not being solely for charitable purposes.

Which sections of the Income-tax Act were involved?

Section 80G(5)(iii),Section 80G,Section 2(15)

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Income Tax Appellate Tribunal, RAJKOT BENCH, RAJKOT

Before: DR. ARJUN LAL SAINI & SHRI DINESH MOHAN SINHA

For Appellant: Shri Rajendra Singhal, AR
For Respondent: Shri Sanjay Punglia, CIT DR
Hearing: 03/06/2025Pronounced: 21/07/2025

Per, Dr. A. L. Saini, AM: Captioned appeal filed by the assessee, is directed against the order passed by the Learned Commissioner of Income Tax (Exemption), Ahmedabad [ in short, ‘Ld.CIT(E)’] vide order dated 24.12.2024, wherein Ld. CIT(E) has denied the approval under Section 80G(5)(iii) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) holding that assessee has violated existing main condition of sub-Section (5) of Section 80G and Explanation 3 to Section 80G of the Act and Clause(ii) of sub- Section(5) of Section 80G of the Act.

The order continues below.

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