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We acknowledge regarding the show cause for our application filed in Form 10AB under section 80G(5)(iii) of the Income Tax Act, 1961. We understand the concerns raised and would like to provide the following clarifications:

Page | 3 ITA NO. 31/RJT/2025 Anandabava Seva Sanstha Gaushala Trust Charitable Objectives: Our trust is dedicated to numerous charitable activities that benefit the community at large. These activities include but are not limited to social philantrophic activites that includes providing food and support to slum children and poor families and building and management of old age homes, orphanages-schools- colleges without any caste discrimination religious activities, these constitute only a minor portion of our overall operations. The primary focus of our trust remains on charitable activities that serve the public good without discrimination.
Compliance with Section 10AB: We believe that our trust meets the criteria set forth under Section 10AB, as the predominant purpose of our trust is charitable in nature. The inclusion of some religious activities does not detract from our primary charitable objectives. Impact on Beneficiaries: Rejecting our application would adversely affect the cows which are maintained by the trust & major source of revenue of the trust is from Donation income, If our application is rejected it would also affect the charitable objects of the trust which is also dependent on donation source. We urge you to consider the broader impact on the community and the essential services we provide.

i. The Hon'ble Supreme Court in CIT v. Dawoodi Bohra Jamat, [2014] 43 taxmann.com 243/222 Taxman 228/364 ITR 31 (SC) had observed that the objects of trust as declared in the Trust Deed would govern its right of exemption under sections 11 and 12 of the Act. The Hon'ble Supreme Court also recognized the creation or establishment of trust for either religious or charitable or both religious charitable purposes. By looking at the objects of the trust, it had to be determined whether the objects were wholly religious or wholly charitable or both religious and charitable and it was held that on consideration of the objects of the trust, the religious and charitable purposes and activities of the trust could be determined. It was further held that section 11 of the Act allows such trust with composite objects to claim exemption from tax as a religious and charitable trust, subject to provisions of section 13 of the Act. Though the objects of the trust were based on religious tenets but where the activities of the trust for both charitable and religious were not exclusively meant for a particular religious community, then it would not fall under the provisions of section 13(1)(b) of the Act and it was further held that where the assessee was charitable and religious trust, which did not benefit any specific religious community and hence, it could not be held that the provisions of section 13(1)(b) of the Act would be the Act. The relevant observations of the Hon'ble Supreme Court are as under: -

(ii) That the objects of the assessee-trust were not indicative of a wholly religious purpose but were collectively indicative of both charitable and religious purposes. Although objects (c) and (f) which provided for activities completely religious in nature and restricted to the specific community of the assessee-trust were objects with religious purpose only, the fact that the other objects traced their source to the Holy Quran and resolved to abide by the path of godliness shown by Allah would not be sufficient to conclude that the entire purpose and activities of the trust were purely religious in colour. The objects reflected the intent of the trust as observance of the tenets of Islam, but did not restrict the activities of the trust to religious obligations only and for the benefit of the members of the community. The provision of food to the public on religious days of the community, the establishment of Madarsas and organisations for dissemination of religious education and rendering assistance to the needy and poor for religious activities would reflect the essence of charity. The activity of providing for food on certain specific occasions and other religious and auspicious events of the Dawoodi Bohra community did not restrict the benefit to the members of the community. Neither the religious tenets nor the objects as expressed limited the service of food on these occasions to members of the specific community. The establishment of Madarsas or institutions to impart religious education to the masses would qualify as a charitable purpose qualifying under the head of education under the provisions of section 2(15) of the Act. Similarly, assistance by the Page | 8 ITA NO. 31/RJT/2025 Anandabava Seva Sanstha Gaushala Trust assessee-trust to the needy and poor for religious activities would not divest the trust of its altruist character. Therefore, the objects of the trust exhibited the dual tenor of religious and charitable purposes and activities. Section 11 of the Act allowed such trust with composite objects to claim exemption from tax as a religious and charitable trust subject to the provisions of section 13. The Activities of the trust under such objects would, therefore, be entitled to exemption accordingly.