Sattavis Kadva Patidar Pragati Mandal Vs CIT (ITAT Ahmedabad)
The case of Sattavis Kadva Patidar Pragati Mandal v. CIT before the Income Tax Appellate Tribunal (ITAT) of Ahmedabad addressed the rejection of a trust’s application for final registration under Section 80G(5) of the Income Tax Act, 1961. The core issue was whether a trust with some religious objects, even without incurring any religious expenditure, could be denied the benefit of a Section 80G exemption, which allows donors to claim a deduction for their contributions.
The assessee, Sattavis Kadva Patidar Pragati Mandal, is a trust registered under the Gujarat Public Trust Act, 1950. Its objectives are predominantly charitable, including educational, social, and health-related activities, though its trust deed also lists a small number of religious objectives. The trust had already secured a Section 12A registration, which is a prerequisite for exemption under Section 11 of the Income Tax Act. It had also been granted provisional registration under Section 80G. However, its application for final 80G registration was rejected by the Commissioner of Income Tax (Exemption), who relied on the presence of the religious objects in the trust deed. The Commissioner’s decision was based on a judicial precedent, specifically the Supreme Court’s ruling in Upper Gange Sugar Mills Ltd. vs. CIT.
