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ITAT Pune Remands Case on 80G Registration Denial over Pooja Expense Misclassification

Case Law Details

TaxGuru Citation
2025 taxguru.in 10062
Case Name
Life Eternal Trust Vs CIT (ITAT Pune)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
N. A.
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Life Eternal Trust Vs CIT (ITAT Pune)

This appeal was filed by the assessee, Life Eternal Trust, against the order dated December 21, 2024, passed by the Commissioner of Income Tax (CIT), Exemption, Pune, which rejected the trust’s application for registration under Section 80G(5) of the Income Tax (IT) Act, 1961.

The Application and Rejection

The assessee filed an application for registration under Section 80G(5) of the IT Act on June 29, 2024, to allow donors to claim deductions.

The CIT, Exemption, issued a notice requesting information to verify the genuineness of the trust’s activities and fulfillment of the conditions laid down in clauses (i) to (v) of Section 80G(5). The CIT, Exemption, noted certain discrepancies and issued a subsequent notice asking the assessee to clarify that “pooja expenses” debited in the account, which are religious in nature, were not in excess of 5% of the trust’s total income.

The trust responded that these expenditures were not pooja expenses but were related to Sahaj Yoga, a meditation practice taught by Shree Nirmala Devi, which the trust claims is non-religious in nature and beneficial to the public at large. The trust contended that the term “Pooja” was used colloquially for public understanding and did not involve the worship of specific deities.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,835

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