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1.2 The assessee in its several replies/explanations placed before the Assessing Officer, asserted that the assessee was both a religious as well as charitable trust, and hence it fell within the exception set out in Section 115BBC(2)(b) of the Act. The assessee also pointed out that there were several places of worship within its premises, which evidenced that the assessee was a trust with mixed objects i.e., both charitable and religious. Insofar as the certificate held by the assessee under Section 80G of the Act was concerned, we submit that the term'charitable purpose' as defined in Explanation 3 below Section 80G, excluded only those entities whose purpose wholly or substantially wasreligious in nature. The entities having mixed charitable and religious purpose were not excluded.

Submission 3.1 The appellant, a religious and charitable trust, is engaged in activities aimed at furthering education, spiritual learning, and social welfare. As part of its educational and research activities, the Trust purchased books and periodicals for the purpose of enhancing its library resources and supporting its educational initiatives. The total expenditure on these books and periodicals amounted to Rs. 12,825/-.

3.2 Under Section 11 of the Income-tax Act, the income applied for charitable purposes, including the advancement of education, is exempt from taxation. The purchase of books and periodicals is directly related to the Trust's educational objectives and, thus, qualifies as an expenditure for charitable purposes. Therefore, the amount spent on such purchases should have been allowed as a deduction while calculating the Trust's taxable income.

The appellant further prays that the Tribunal issue appropriate directions to ensure that taxpayers are not unfairly penalized for procedural matters when they are entitled to relief.

That during the year the sansthaan has paid Rs.1.00 Crore to Rajasthan State Unviersity as endowment fund and this is application of income by the sansthaan. The appellant request your honour to kindly allow us deduction of the aforesaid application of income while calculating taxable income.

Submission 7.1 The Trust has been established with the objective of promoting religious, educational, and charitable activities, and it operates a temple, a gaushala, and engages in regular charitable activities, including conducting bhandaras for the needy. Recently, the Trust has expanded its scope by initiating plans to establish a Vedic university. As part of these initiatives, the Trust contributed Rs. 1.00 Crore to Rajasthan State University as an endowment fund to support educational endeavors, which aligns with the Trust's charitable and educational objectives.

From the above, it is clear that the Assessing Officer (AO) has misinterpreted the legal provisions of Section 115BBC and erroneously made an addition despite acknowledging that the trust serves dual purposes, encompassing both religious and charitable objectives.

We also submit that the Trust operates a temple, where traditional forms of worship are conducted by devotees. All the attributes of religious activities, including rituals, poojas, and ceremonies, are performed regularly, particularly on different festivals, as per established practices.This also has been affirmed by Ld. CIT Appeals in the above Para. In support of this, we are enclosing photographs of the temple and activities carried out by the Sansthanonpage no. 17 to 29 and news paper cutting Page No. 30 to 84 of currentPaper Book.