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Section 80G Approval Cannot Be Denied for Puja Expenses
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ITAT Delhitax

Section 80G Approval Cannot Be Denied for Puja Expenses

September 28, 2026

ITAT Delhi grants 80G approval to temple, ruling religious activities do not negate charitable purpose.

Section 80G Approval Cannot Be Denied for Puja Expenses

The ITAT Delhi allowed 80G approval for Dwarka Kalibari, holding that expenditure on pujas and religious rituals does not disqualify an institution from being charitable under Section 2(15).

The tribunal observed that Hindu temples have long been recognized as charitable entities engaged in religious and spiritual upliftment. Religious worship is an intrinsic part of such institutions’ objectives.

Denial of 80G solely on the basis of religious expenditure runs counter to judicial precedents and the legislative intent of promoting charitable giving.

This decision protects religious institutions from arbitrary denial of tax-exempt status. It aligns with broader interpretations of charity under the Act. Assessing authorities must evaluate the overall charitable character, not single out religious activities.

Citations

  • Section 2(15), Income Tax Act
  • Section 80G, Income Tax Act
Practice Areas:tax
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