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8. After the formation of the Trust, the assessee conducted various workshop to disseminate the knowledge of Vedas. General public irrespective of caste, creed, gender or "religion were invited to witness the said events and to know the significance and importance of Vedas. The Vedic Scholars were identified and felicitated irrespective of their caste, creed or religion. The assessee-trust has given financial assistance to various people, irrespective of caste, creed or religion, involved in Indian Heritage Education. Trust conducts teaching of Vedas by various scholars to students, working people, retired persons etc. irrespective of caste, creed, religion. The trust has conducted the vedic classes by going to the houses of all interested people irrespective of caste, creed, gender or religion and has taught them the importance of Vedas. During Covid, the trust provided financial assistance to the poor Vedic scholars and distributed food kit, cloths, medicines for the needy. All the expenses to carry out the above charitable objectives are met out of donations received. No fees or honorarium or money is charged by the trust or by any Trustees for conducting the vedic classes, chanting or for any programmes. All trustees work selflessly for achieving the charitable objects of the Trust.

case of Upper Ganges Sugar Mills (supra) was laid down while dealing the case of deduction u/s. 80G of the Act in the hands of donor so also in the case of Sri Marudhar Kesari Sthanakwasi Jain Yadgar Samiti Trust (supra) by this Court, those judgments do not advance cause of the revenue. On the other hand, the case laws relied upon by the learned counsel for the petitioner fully support the case of the petitioner when the Courts have consistently held that it is the dominant object of the trust which is important and contribution and expenditure incurred by the petitioner-trust has to be viewed in light of the objects with which charitable trust in question was constituted."

21. In the above judgment, it was held by the Hon'ble Rajasthan High Court that approval u/s. 80G cannot be refused if one particular expenditure was made for repair and renovation of Lord Vishnu's temple and that too by way of contribution to another trust. Relevant observations are as under:-

"The line of distinction between religious purposes and charitable purposes is very thin and no watertight compartment between the two activities can be established. Unless the objective of the charitable trust in question itself is to spend its income for a particular religion and it is so found in the trust deed, the Income-tax Department cannot reject the renewal of the trust as charitable trust u/s. 80G of the Income-tax Act, 1961, merely because one particular expenditure is for an activity which may be termed as spending for a particular religion."

13. In light of the above factual matrix and respectfully following the order of Banglore bench of Tribunal (supra) we find that the objects of the trust are charitable in nature. The activities of conducting structured Sanskrit courses amount to "education" within section 2(15). Charging nominal fees does not negate charitable character. Non-commencement of certain objects is not fatal at registration stage. The ld.CIT(E) erred in law and on facts in rejecting the application. Accordingly, the impugned orders dated 21.03.2025 are set aside. The Ld. CIT(E) is directed to grant registration to the assessee u/s. 12AB and approval u/s.80G of the Act.