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ITAT Jodhpur Allows 80G Approval Where Religious Spending Remains Below 5%

Case Law Details

TaxGuru Citation
2026 taxguru.in 12073
Case Name
Geeta Satsang Ashram Samiti Vs Ward Exemption (ITAT Jodhpur)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2023-24
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Geeta Satsang Ashram Samiti Vs Ward Exemption (ITAT Jodhpur)

Summary: The assessee, Geeta Satsang Ashram Samiti, a registered society, appealed against rejection of its application for approval under section 80G of the Income-tax Act, 1961. The application had been rejected by the Commissioner of Income Tax (Exemption), who treated the assessee as a religious institution and held that expenditure incurred for religious purposes exceeded the permissible limit under section 80G(5B).

The Tribunal recorded that the assessee carries out various charitable activities, including providing food to poor persons through Annakshetra, organising medical camps, distributing medicines and disseminating spiritual and philosophical teachings of the Bhagavad Gita. The application for approval under section 80G had originally been filed on 29.09.2022. An earlier rejection dated 20.03.2023 was challenged before the Tribunal, and the Jaipur Bench, by order dated 07.08.2023 in ITA No. 258/JP/2023, restored the matter to the CIT(E) for fresh consideration after giving the assessee an opportunity to furnish requisite documents. The assessee thereafter furnished detailed submissions dated 15.12.2025 and 21.01.2026 with supporting documents and accounts. The CIT(E) again rejected the application, principally on the basis that the objects contained elements of religious activities and that 54.44% of expenditure had been incurred on religious activities.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,689

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