Shrthiparampara Gurukulam Vs ITO (ITAT Bangalore)
The case of Shrthiparampara Gurukulam vs. ITO addresses the classification of a public charitable trust dedicated to teaching Vedas, a central issue with significant implications for tax exemption under the Income Tax Act of 1961. The Income Tax Appellate Tribunal (ITAT) of Bangalore heard an appeal from the assessee, a trust formed to preserve and teach the Rigveda in a traditional Gurukulam style. The core of the dispute was whether the trust should be registered as a “charitable” or “religious” institution, as this classification determines its eligibility for approval under Section 80G of the Act, which provides tax deductions for donors.
Factual Background and Lower Authority’s Decision
The trust, established on July 8, 2021, by a Vedic scholar, had objectives focused on preserving and teaching the Vedas, Sanskrit, Indian heritage, and culture. The trust deed specified that its beneficiaries were members of the general public, regardless of race, religion, caste, community, creed, or gender. After receiving provisional registration under Sections 12A and 80G, the trust applied for regular registration.
The CIT (Exemptions), however, granted registration under Section 12A but classified the trust as “religious.” Subsequently, the CIT(E) rejected the trust’s application for approval under Section 80G, citing that the teaching of Vedas—a Hindu religious scripture—is an activity “the whole or substantially the whole of which is of a religious nature,” as per Explanation 3 to Section 80G. This decision was based on the premise that the trust was primarily for religious purposes and benefited only a particular religious community, thus disqualifying it from the Section 80G tax benefits.
