Shrouta Vijnan Gurukulam Vs ITO (Exemptions) (ITAT Bangalore)
The case of Shrouta Vijnan Gurukulam Vs ITO (Exemptions) before the Income Tax Appellate Tribunal (ITAT), Bangalore, centered on the eligibility of a trust for tax benefits under Section 80G of the Income Tax Act, 1961. The assessee, Shrouta Vijnan Gurukulam, is a trust founded with the primary objective of teaching and spreading Vedic education. The dispute arose after the Commissioner of Income Tax (Exemptions) (CIT(E)) rejected the trust’s application for approval under Section 80G, arguing that its activities were “religious in nature” and thus ineligible for the exemption.
Background and CIT(E)’s Holding
Shrouta Vijnan Gurukulam, a trust established in 2013, had previously been granted registration under Section 12A and approval under Section 80G. However, upon a new application, the CIT(E) rejected the trust’s request. The CIT(E)’s decision was based on Explanation 3 to Section 80G, which states that “charitable purpose” does not include any purpose that is “the whole or substantially the whole of which is of a religious nature.” The CIT(E) concluded that the trust’s objects and activities, focused on “teaching of vedas,” were religious, and therefore, it did not qualify for approval.
Assessee’s Argument and Judicial Precedents
The trust appealed the decision to the ITAT, contending that teaching Vedas is not a religious activity but rather a form of education and a way of life. The trust’s counsel presented several judicial precedents to support its claim, arguing that the CIT(E)’s interpretation of “religious” was flawed.
