In a significant ruling, the Income Tax Appellate Tribunal (ITAT), Ahmedabad has held that a charitable trust cannot be denied approval under Section 80G of the Income Tax Act merely because one of its objects involves organising programmes such as Ramkatha, Bhagwat Katha, or similar spiritual gatherings for fundraising purposes.
The tribunal clarified that such activities cannot automatically be treated as wholly religious in nature, especially when the primary purpose of the trust remains charitable.
ITAT Ahmedabad’s Key Observation
A bench comprising Judicial Member Sanjay Garg and Accountant Member Narendra Prasad Sinha observed that the trust’s object of conducting Ramkatha and Bhagwat Katha:
- cannot be considered wholly or substantially religious, and
- does not amount to propagation of any religion.
The tribunal emphasised that these programmes are often organised for the welfare of society and moral upliftment, rather than religious promotion.
Background of the Case
The assessee, Dharamdas Charitable Trust, registered under Section 12A, applied for approval under Section 80G(5) to enable donors to claim tax deductions.
However, the Commissioner of Income Tax (Exemption), Ahmedabad rejected the application on the ground that one of the trust’s objects appeared religious.
The objection related to an object permitting the trust to organise:
- Ramkatha
- Bhagwat Katha
- Navchandi Yagna
- Gayatri Yagna
primarily for raising funds.
Trust’s Broader Charitable Activities
The tribunal noted that apart from the disputed object, the trust was engaged in multiple charitable purposes, including:
- establishing educational institutions
- distributing books and uniforms to needy students
- providing computer training
- setting up blood banks and medical centres
- helping the poor and disaster victims
- running food and drinking water centres
- supporting widows, orphans, and underprivileged persons
- maintaining animal shelters
These objects clearly fell within the definition of charitable activities under the Act.
Tribunal’s Reasoning
While addressing the fundraising programmes, the ITAT observed that Ramkatha and Bhagwat Katha are conducted for the benefit of the public at large, irrespective of religion.
The tribunal explained that such events:
- promote moral and spiritual well-being
- encourage good conduct in society
- help individuals lead peaceful and ethical lives
- serve as a means to raise funds for charitable activities
It further held that the trust did not intend to propagate religion, but instead aimed to utilise the funds generated for welfare measures such as medical relief and helping the poor.
Final Verdict: 80G Approval Directed
The ITAT concluded that there was no valid justification for rejecting the trust’s application under Section 80G.
Accordingly, it set aside the Commissioner’s order and directed the authority to grant 80G approval to Dharamdas Charitable Trust from the date of application.
Case Details
- Case Title: Dharamdas Charitable Trust v. CIT (Exemption), Ahmedabad
- Case Number: I.T.A. No. 73/Ahd/2025
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Citation: 2026 LLBiz ITAT(AHM) 26