To propagate philosophy of all religious and spiritual reformers with special emphasis on vegetarianism is nothing but a public charitable object
In the instant case the assessee-trust was registered under section 12AA. It was also granted exemption under section 80G. Subsequently, its object clause was enlarged including the object of propagating the messages, teachings, ideals and philosophy of all the religious and spiritual reformers with special emphasis on vegetarians. Its application seeking renewal of exemption under section 80G(5) was rejected by the CIT holding that it was pursuing religious objects and was not eligible for exemption.
The Tribunal held in favour of assessee:
1) The added object of the trust, did not seem to be wholly or substantially a religious one. The teachings of gurus with a view to spread vegetarian way of life would definitely save the wild life and would help in preserving environment;
2) Thus, without viewing the meaning of the above object from a limited aperture whose simple use of the word 'religion' was taken as otherwise was unfortunate;
3) It is the religion which teaches one and all the way of life. How, one could live physically, mentally and socially happy and prosperous, is taught by one and all religions. So, it was religion in that wider sense of its meaning and not in the way of limited meaning of segmentalization of society and creating a divide in the society;
4) The meaning of public-charity goes on changing but the main idea of charity remains static. The above object was for public charity and was not limited to a particular class or believer in a particular section. Therefore, the CIT was to be directed to grant approval to the assessee-trust under section 80G(5) - KUKA MARTYRS MEMORIAL TRUST V. CIT (2013) 35 taxmann.com 516 (Chandigarh - Trib.)