Propagating Vedic knowledge is charitable, not religious, entitling

Propagating Vedic knowledge is charitable, not religious, entitling the trust to Section 80G tax approval.

Issue

Whether an assessee-trust engaged in the propagation of Sanatana Dharma, Vedas, Bhagavad Gita, and related works can be classified as a “religious cum charitable trust” without any specific reasons assigned by the CIT(Exemptions).
Whether the classification as a “religious cum charitable trust” under Section 12AB can be grounds to deny tax approval under Section 80G of the Income-tax Act, 1961.

Facts

The assessee-trust was formed under the Indian Trusts Act with core objects to spread awareness of Sanatana Dharma, Vishishtadvaita, and Ubhayavedanta.
Its objectives included promoting spirituality among the public and disseminating the knowledge and messages of the Bhagavad Gita, Vedas, Divyaprabandhas, and Itihasa Puranas through classes, lectures, camps, discourses, and demonstrations.
The trust applied for registration under Section 12A(1)(ac)(i) of the Income-tax Act, 1961.
The CIT(Exemptions) granted registration under Section 12AB(1)(b) but unilaterally categorized the trust as a “religious cum charitable” trust without providing reasons.
In a subsequent separate order, the CIT(Exemptions) denied approval under Section 80G solely on the basis that the trust was designated as “religious cum charitable” in its Section 12AB registration.

Decision

Re-classification Directed: The classification of the trust as “religious cum charitable” was improper, as the CIT(Exemptions) failed to assign valid reasons and erred in assuming that propagating Vedic knowledge constitutes a purely religious activity.
Precedents Applied: Relying on the principles laid down by the Supreme Court in Sole Trustee, Loka Shikshana Trust v. CIT [1975] and the Madhya Pradesh High Court in Maharishi Mahesh Yogi Vedic Vishwavidyalaya v. State of MP [2002], the propagation of Vedic texts and ancient scriptures falls under the advancement of education and general public utility (charitable purposes), rather than religious activity.
Section 80G Approval Granted: The CIT(Exemptions) was ordered to strike the word “religious” from the classification of the assessee-trust and grant the sought approval under Section 80G.

Key Takeaways

Teaching Sacred Texts as Education: Propagating spiritual, philosophical, or traditional texts like the Vedas and Bhagavad Gita constitutes educational/charitable activity rather than a religious purpose under income tax law.
Reasoned Orders Required: The Revenue authorities cannot arbitrarily label an entity as a religious trust without issuing a reasoned order supported by facts.
Removal of Section 80G Obstacles: Misclassification during Section 12AB registration cannot automatically be used as a tool to deny deduction benefits to donors under Section 80G.

IN THE ITAT CHENNAI BENCH ‘A’

Kinchitkaram Trust

Commissioner of Income-tax (Exemptions)

Manu Kumar Giri, Judicial Member
and Inturi Rama Rao, Accountant Member

IT Appeal Nos. 3348 (CHNY) of 2025 and 3102 (CHNY) of 2026

AUGUST 20, 2026

Raghavan Ramabadran, CA for the Appellant. Ms. R. Anita, CIT for the Respondent.

ORDER

Inturi Rama Rao, Accountant Member.- These are two appeals filed by the assessee are directed against the separate orders of Learned Commissioner of Income Tax(Exemption), Chennai denying grant of approval u/s.12AB(1)(b) and 80G of the Income Tax Act, 1961 both dated 27.03.2026.

2. Since identical facts and issues are involved in both these appeals, these appeals were heard together and disposed of by this common order. For the sake of clarity and convenience the facts relevant in the ITA No.3102/CHNY/2026 are stated herein:

3. The Assessee raised the following grounds of appeal :

“1. That the Ld. CIT(E) has erred in declining to recognize the Appellant Trust as a ‘charitable’ trust without assigning any cogent reasons or justification for such denial, insofar as the said order characterizes the Appellant Trust as ‘religious cum charitable’, and the Appellant seeks classification as ‘charitable’ alone.

2. That the Ld. CIT(E) erred in treating the Appellant Trust as ‘religious cum charitable’, without appreciating the fact that there has been no change in the nature of activities carried on by the Appellant Trust, and without taking into account that the earlier registration granted to the Appellant also considered the Appellant as ‘charitable’.

3. The Ld. CIT(E) has erred in concluding that the Appellant Trust is ‘religious cum charitable’ in nature, without duly considering that the activities undertaken by the Appellant are purely charitable and devoid of any religious character.

4. The Ld. CIT(E) has erred in concluding that the Appellant Trust is a ‘religious cum charitable trust without undertaking an independent examination of the Appellant Trust’s activities and has instead relied upon the rejection order passed under section 80G of the Income-tax Act, 1961 dated 30.09.2025, which is presently the subject matter of appeal before the Hon’ble Income Tax Appellate Tribunal. In doing so, the Ld. CIT(E) has not independently examined the Appellant’s activities, and reliance on such an order, which is under appellate consideration, is not justified.

5. That the Ld. CIT(E) failed to appreciate that the Appellant Trust has, for several years, consistently filed its returns in the status of a charitable trust and the same have been accepted and assessed by the Department as such.”

ITA No.3102/CHNY/2026 :

4. Briefly the facts of the case are that the appellant is a Trust incorporated under the provisions of Indian Trust Act. It is formed with the following objects:

(a)

To spread awareness of, inculcate belief in, Sanatana Dharma in general, Vishishtadvaita and Ubhayavedanta in particular, its teaching, practices and encourage following and observance thereof.

(b)

To encourage spirituality amongst the masses especially youth and children

(c)

To spread the meaning, understanding, message of Bhagavat Gita, Veda, Vedanta, Divyaprabandhas, Itihasa Puranas and other works, literature pertaining to Sanatana Dharma in general, Vishishtadvaita and Ubhayavedanta in particular.

(d)

To hold, run classes, lectures, camps, discourses, demonstrations, on topics relevant to Sanatana Dharma in general, Vishishtadvaita and Ubhayavedanta in particular.

5. The appellant trust applied for grant of registration u/s.12A(1)(ac)(1) of the Act in Form No.10AB on 05.03.2023.

6. The learned CIT(Exemptions), Chennai after duly considering the objects of the Trust as well as the information furnished in response to notice issued by the Learned CIT(Exemptions) had granted registration u/s.12AB(1)(b) of the Act vide order dated 27.03.2026. However, the Learned CIT(Exemption) classified the appellant-trust as ‘religious cum charitable trust’.

7. Being aggrieved by this classification, the appellant is in appeal before us in the present appeal. The Learned Counsel submits that imparting of Vedic Education is not a religious activity but it is a way of life. In support of this proposition, the learned Counsel relied on the following decisions :

“B.14. At the outset, it is submitted by the Appellant that the Ld. CIT (E) has flawed and misinterpreted the very basic tenet that Hinduism is a way of life and cannot be construed as a religion. To substantiate the same, reliance is placed on the following decisions –

Hon’ble SC in Dr. Ramesh Yeshwant Prabhoo v. Shri Prabhakar Kashinath Kunte & Ors 1996 AIR 1113 (SC) wherein it was held that Hindutva is a way of life or a state of mind and cannot be equated with Hindu fundamentalism.

Hon’ble High Court, Madras in T.T. Kuppuswamy Chettiayar & Ors v. State of Tamil Nadu (1987) 100 LW 1031 wherein it was held that a study of the Sanskrit texts in English and law administered in pursuance thereof, clearly shows that there is no religion by the name ‘Hindu’. Further, it was observed that a perusal of the word ‘Hindu’ was given by the British authorities while dispensing justice with reference to the inheritance, partition, marriage and other personal laws of the inhabitants of this nation who are not Muslims, Christians, Buddhists, Jains.

Hon’ble ITAT, Nagpur in Shiv Mandir Devsttan Panch Committee Sanstan v. CIT, Nagpur ITA No. 223 (Nagpur) of 2009 wherein it was held that Hinduism is neither religion nor a community. Even worship of God is not essential for a person who has adopted Hinduism way of life. Thus,

Hinduism holds within its fold men of divergent views and traditions who have very little in common except a vague faith in what may be called the fundamentals of Hinduism.

Meaning of the term ‘Vedas’ and their interpretation thereof-

B.15. It now becomes pertinent to analyze as to the meaning of the term ‘Vedas’ and whether the same can be construed to fit within the ambit of ‘religion’.

B.16. Vedas are the means for attaining knowledge, happiness through wisdom and self -realization which are beyond the sphere of perception of inference. Vedas give emphasis on the values of life and the said values have universal relevance. [Excerpt from the decision of the Hon’ble High Court in Maharishi Mahesh Yogi Vedic Vishwavidyalaya v. State of MP (2002) SCC OnLine MP 191].

B.17. It is submitted by the Appellant that the concept of vedas is not limited to the recital of sastras, but is also scientifically all-encompassing. To substantiate the same, reliance is placed on the decision of the Hon’ble High Court, Madhya Pradesh in Maharishi Mahesh Yogi Vedic Vishwavidyalaya v. State of MP (2002) SCC OnLine MP 191. In the said decision the Assessee is a university that is incorporated u/s 3 of the MP Vishwavidyalaya Adhiniyam, 1973. The said Assessee was established to provide full-fledged education on the vedas and professional, vocational courses to make the goal of education complete. The said Act provided that the University shall have the power to provide for instruction in such branches of learning as the University may from time to time determine and to make a provision for research and advancement and dissemination of knowledge. Thereafter, an Act by the name Maharishi Mahesh Yogi Vedic Vishwavidyalaya Adhiniyam, 1995 (‘University Act’) came into existence wherein Section 4(i) provided that the University shall have powers to provide for instruction only in all branches of Vedic learnings and practices. Thus, all other institutions established under the original Act could provide education in other areas and the present University vide the University Act could only provide instructions with respect to vedic learnings. The question for consideration was whether Section 4(i) of the University Act which limited the instruction ‘only’ to vedic subjects and requirement for State approval for courses and centres violated Articles 14 and 21 of the Constitution of India. in the decision, the Hon’ble High Court analyzed the concept of ‘vedas’ and noted as follows –

In vedas, there are formulae which deal with mathematics. The vedic sutras enable a person to solve complex mathematical problems because of their cogency, compactness and simplicity.

It is a total misconception that the vedas are only relatable to rituals.

Vedas convey unified sense of knowledge and have given emphasis on pollution – free world and commend prayer for the protection of mother earth and all other elements.

The modern physicists are also connecting certain theories propagated by the ancient Indians. Some scientists have seen atomic dance in the deity of ‘Natraj’. The empirical knowledge which has been achieved, had been perceived by the ancient ‘Drastas’.

The memories of cells, which is the modern discovery finds place in the wise men of the past. The Psychology, Psychiatry, Neurology had also been adverted in their own way in the Shastras. Presently scholars recognize one continuous shining background which had its base in pure consciousness.

Vedic learning is concerned with human anatomy and physiology. The views of the said vedas qua human anatomy coincides more than less with that of medical science today.

The purpose for referring to the concept of Vedas is to show that wisdom of the ancients is being slowly proved by adopting tests by scientific methods.

The same was upheld by the Hon’ble SC in Maharishi Mahesh Yogi Vedic Vishwavidyalaya v. State of MP (2013) 15 SCC 677.

As established supra, considering Hinduism is a way of life and Vedas are scriptures that delve into various ideals, they cannot be ascribed to form part of any religion.

It is also pertinent to put forth that the Ld. CIT (E) vide Para 4.3.2 held that the activities of the Appellant include study of Divya Prabandham, a 4000-verse Tamil anthology of hymns sung in praise of Lord Vishnu and hence, concluded that the Appellant is engaged in propagation of a religious scripture.

At this juncture, it is submitted by the Appellant that Divya Prabandham sung by Nammazhwar is the tamizh version of Upanishad of Vedas. Divya Prabandham is also referred to as Tamizh Vedas / Senthamizh Vedas. “Tamizh’ in Sanskrit language is referred to as ‘Dramid’ which references ‘Dravid’. Thus, Divya Prabandham is referred to as Dravida Veda Sagaram. It is submitted by the Appellant that to increase the outreach of Vedas and to capture the essence of Vedas in Tamizh, the knowledge in Divya Prabandham is inculcated to the students in the Veda Pathasala.

B.22. Considering that Divya Prabandham is the Tamizh version of Vedas, the same cannot be construed as a religious activity, thus dis-entitling the Appellant of approval under Section 80G of the IT Act.

Tradition of vedic chanting is part of intangible cultural heritage

B.23. The United Nations Educational, Scientific and Cultural Organization (‘UNESCO’) in 2003 adopted a Convention for the Safeguarding of the Intangible Cultural Heritage (‘Convention’). The purpose of this Convention was to safeguard, respect and raise awareness at local, national and international levels of the intangible cultural heritage. Article 2(1) of the Convention defines intangible cultural heritage to mean practices, representations, expressions, knowledge, skills, etc transmitted from generation to generation recreated by communities and groups in response to their environment, their interaction with nature and their history. The same provides them with a sense of identity and continuity, in turn promoting cultural diversity and creativity. Intangible cultural heritage can be oral traditions and expressions including language; performing arts; social practices, rituals and festive events; knowledge and practice concerning nature and the universe; and traditional craftmanship. The Committee established under this Convention working alongside the Parties to the Convention is responsible for publishing a Representative List to ensure better visibility of intangible cultural heritage and drawing awareness to its significance.

B.24. The tradition of Vedic chanting forms a part of the 2008 Representative List and is considered a part of intangible cultural heritage by UNESCO. The value of this tradition lies in the rich content of its literature i.e. the Vedas and the ingenious techniques adopted to preserve the same. To ensure the sound of each word remains unaltered, complex recitation techniques based on tonal accents and a unique manner of pronouncing each letter and specific speech combinations is taught from childhood. UNESCO noted however that out of over one thousand vedic recitation branches, only thirteen have survived and four more schools are considered to be under imminent threat. The tradition of vedic chanting is significant in achieving the Sustainable Development Goal No. 4 of ensuring Quality Education.

B.25. In light of the above, the establishment and sustenance of a Veda pathasala as operated by the Appellant ensured structured training in the intricate oral techniques of Vedic chanting. these institutions safeguard a heritage that UNESCO has recognized as vital to global cultural diversity. In a time where only a handful of recitation branches subsist, Veda pathasalas such as the one operated by the Appellant serve as living repositories of knowledge, ensuring continuity, identity and creativity for future generations. The role of the Appellant is indispensable in preserving this intangible cultural heritage and in advancing sustainable development goals of quality education.

B.26. Reliance in this regard has been placed on the decisions of Sri Ashvalayana Vrunda v. ITO [ITA No. 1084/Bang/2022]; Shri Shruthiparampara Gurukulam v. ITO [ITA Nos. 1082,1083/Bang/2022]; and M/s Shrouta Vijnan Gurukulam v. ITO [ITA No. 694/Bang/2024] wherein the Hon’ble ITAT has underlined the importance of imparting vedic education in light of the Convention.

Judicial decisions on interpretation of’Vedas’ vis-a-vis approval u/s 80G of the IT Act

B.27. It is submitted by the Appellant that there are various judicial decisions wherein the Courts have consistently held that imparting Vedic education does not constitute a religious purpose and hence, the Trusts shall be entitled to approval u/s 80G of the IT Act.

B.28. In the decision of the Hon’ble ITAT, Bangalore in Shri Shruthiparampara Gurukulam v. ITO [ITA Nos. 1082,1083/Bang/2022], the Assessee was created with an objective of preaching Rigveda in a traditional Gurukula concept. The application for approval u/s 80G was denied on ground that the Assessee was engaged in a religious activity of teaching vedas, a Hindu religious scripture to Hindu students. The Hon’ble ITAT held that the beneficiaries of the Trust are members of general public irrespective of race, religion, caste, community, creed or gender. The word ‘veda’ means knowledge and signifies highest sacred, eternal and divine knowledge as well as the texts embodying that knowledge. Apart from philosophy, there are descriptions of various aspects of different subjects. The Hon’ble ITAT held that the Assessee only teaches the students how to recite vedas. There is a particular method of pronunciation of vedas with swaras attached to it. The recitation of vedas is like teaching any other Sanskrit literature and does not involve offering worship and prayer to God. Hence, the approval u/s 80G of the IT Act must be granted to the Assessee.

B.29. Against the same, an appeal has been preferred by the Department before the Hon’ble High Court, Karnataka, which is still pending. However, the Order of the Hon’ble ITAT has not been stayed by the Hon’ble Kerala High Court and hence, continues to be a binding precedent.”

B.30. In addition to the decision of the Hon’ble ITAT, Bangalore discussed above, similar principles have been affirmed in rulings of other Benches, including Chennai, Delhi, and Indore, as captured in the table herein below:”

8. Based on the legal position enunciated in the above decisions, the learned Counsel submits that propagation of vedas does not amount to religious activity. Therefore, he submits that the classification given by the Learned CIT(Exemption) is patently wrong.

9. On the other hand, learned CIT-DR opposed the above submissions.

10. We heard the rival submissions and perused the material on record. The sole issues that arises for our consideration is whether the Learned CIT(Exemption) was justified in classifying the appellant-trust as a charitable cum religious trust. On mere perusal of the impugned order before us, it would reveal that the learned CIT(Exemption) had classified the appellant-trust as a charitable cum religious trust. Even though the learned CIT(Exemption) had not given any reasoning for such classification, based on the material available on record, we presume that perhaps the learned CIT(Exemption) was swayed by the fact that the appellant-trust was engaged in the propagation of vedas. In view of the legal position enunciated in the decisions of the Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) and Hon’ble Madhya Pradesh High Court in the case of Maharishi Mahesh Yogi Vedic Vishwavidyalaya v. State of MP 2002 SCC OnLine MP 191 cited (supra), we are of the considered opinion that the appellant-trust cannot be classified as a “religious cum charitable trust”, accordingly, we direct the Learned CIT(Exemption) to remove the word “religious” in the classification of the trust.

11. In the result, appeal filed by the assessee stands allowed.

ITA No.3348/CHNY/2025 :

12. On bare perusal of the impugned order, it would be clear that the appellant trust was denied the approval u/s.80G of the Act for the reason that the appellant-trust was classified as “religious cum charitable trust”, while seeking registration u/s.12AB(1)(b) of the Act. In the appeal filed by the appellant-trustQ against the order u/s.12AB(1)(b) of the Act in ITA No.3102/CHNY/2025, we had directed the Learned CIT(Exemption) to delete the word “religious” from the classification of the trust for the reasons stated therein. Since the reasoning adopted by the Learned CIT(Exemption) for denial of approval u/s.80G of the Act was held to be untenable in law by us in the appeal filed against order u/s.12AB(1)(b) of the Act, we direct the Learned CIT(Exemption) to grant the approval u/s.80G of the Act to appellant-trust.

13. In the result, appeals filed by the assessee stands allowed.