Vedic Gurukulam is “Charitable,” Not “Religious,” for Tax Exemption: ITAT Bangalore

Explanation 3 to s. 80G provides that “charitable purpose” does not include a purpose which is of a “religious nature”. The ITAT Bangalore bench in M/s Sri Channamallikarjuna Trust Committee Gangavathi Vs. CIT (E) – ITA No 1829/Bang/2018 (order dated 4.5.2022) explained the difference between charitable purpose and religious purpose and held as under:-“13. In sections 11, 12 & 13, a distinction has been drawn between ‘charitable purpose’ and ‘religious purposes’, but there is no definition of the term ‘religious purpose’ in the Act. Section 13(1)(a) bars exemption to any private religious trust, which does not enure for the benefit of the public. In our considered view, therefore, the appellant-trust qualifies to be a charitable trust as well.