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xxi. To do all such action which are necessary for fulfilling the aims and objectives of the society."

3. Ld. AO noted that assessee trust has been holding spiritual and religious discourses at various samagams (congregations) and also on TV channels. The said discourses are addressed by Brhamrishi Shree Kumar Swamiji known as Gurudevji wherein the participants are imparted mantras i.e. Beej Mantras for providing relief from diseases, mental tension and materialistic worries. The AO noted that in the earlier years the assessee was engaged in imparting of spiritual education, however, in the assessment year 2009-10 and 2010-11, additions were made on account of anonymous donations and same was taxed by invoking provision of section 115BBC. He further noted that during the year, assessee has established a mandir at Greater Kailash Enclave, Part I devoted to Hindu Gods and Goddesses open to general public. He observed that looking into the objects of the trust, which was mainly for charitable purpose but there was no such clause which can call even religious purpose. It is not mentioned information of the 21 clauses incorporated by him in the impugned order. Even in the supplementary trust deeds, there is no alterations or amendments made in the objects of the trust. The activities of the assessee mostly revolves around its religious activities and setting up of temple for worshipping of Hindu God and Goddess and such discourses at every samagam is nothing but imparting of religion lectures. Thus, the assessee trust was not treated or established for religious purpose then it cannot be justified its activities which has now become religious in nature. The objects of a charitable trust is sacrosanct and it is not permissible to go beyond the objects. The assesee before the AO, submitted that it is essentially religious / spiritual and charitable trust and it is engaged in activities of public charity as well as spiritual / religious activities for the upliftment of consciousness of humanity and facilitation for freedom from suffering by way of cosmic grace. The AO released that as per the admission of assesee itself it is purely religious objects and trust was established for religious purpose. Further tried to distinguish the judgement of Hon'ble Apex Court in the case of CIT vs. Social Service Centre 250 ITR 39 (AP) as relied upon by the assesee and also other judgments. He also tried to reject the assessee's contention that objects of the trust include imparting of spiritual lectures and the words spiritual and religious are sacrosanct. The reason given by for such rejection is that in the dictionary these two have been a different connotation. After detailed discussion and looking to the activities carried out by the assesee organising spiritual and other various religious and rituals, he held that thus activities are purely religious and hence asessee is entitled to claim exemption u/s 11 and 12. He also referred to the earlier assessment orders for the assessment year 2009-10 and 2010-11 wherein it was held that assessee and spiritual organisations. However, in this year the facts have changed simply because assessee has set up a temple of Hindu God and Goddess and thus precedence of earlier years will not apply because assessee has decided the issue in favour of the assesee in those years.

9. We have heard the rival submission, perused the relevant finding given in the impugned orders and also in the case of the assessee in the previous years. It is an undisputed fact that based on the objects as enshrined in the trust deed the assessee was given registration u/s 12A and such a registration has neither been revoked nor cancelled by the competent authority . It is a trite law if any proof or institution has been granted registration u/s 12A then income of such trust has to be constituted strictly in accordance with section 11 to 13.This is a which AO has to strictly adhered to. If assesee is not carrying out any activity as per its objects then only the authority granting registration has the power to cancel the registration or view the same. Here in this case , there could not be any dispute that the objects as incorporated in the impugned assessment order as well as in the foregoing paragraphs continues the same as was there in the earlier years. That means there is no change in the objects. The entire case of the AO revolves around the premise that assessee in this year has carried out mainly religious activities simply because assessee has established one Mandir devoted to Hindu God and Goddess. And it is on this fact he has tried to take a divergent view from the earlier years and also not following the precedence of the Tribunal. In para 3 of the assessment order he himself has admitted that trust has been holding spiritual and religious discourses at various Samagam and also on TV channels which are conducted and addressed by Bramrishi Shree Kumar Swamiji wherein the disciples / participants are given imparted that disease, mental tensions and materialist worries. He has also tried to distinguish the words religious and spiritual are two different concepts and they cannot be treated as one and the same and it is for this reason also he has tried to distinguish the past precedence. He further held that intention of the legislature to cover trust for charitable purpose which are for religious for charitable and since here in this case none of the objects are religious, therefore , assessee cannot be held tobe religious trust. We find that the Tribunal after noting down the single objects at para 10.4 have also occasioned to discuss the concept of the term "wholly for religious purposes" or "wholly for religious and charitable purposes". The relevant observations on the findings of the Tribunal in para 10.6 to 10.9 for the sake of ready reference are reproduced hereunder :-