Agama Patashala Education Qualifies as Charitable Activity Under Section 80G: ITAT Chennai Rules in Favour of Vedic Trust
Background and Overview
The Income Tax Appellate Tribunal, Chennai, has delivered a significant ruling in Pasikulam Development Trust Vs CIT (Exemptions), holding that structured instruction imparted through an Agama or Vedic Patashala falls squarely within the definition of "education" and "charitable purpose" under Section 2(15) of the Income-tax Act, 1961. The Tribunal firmly rejected the position that teaching Agama or Vedic scriptures through an organised institution automatically renders such activity "religious" in nature.
The Tribunal set aside the order dated 29.09.2025 passed by the Commissioner of Income Tax (Exemptions), Chennai, which had refused approval to the trust under Section 80G(5) of the Act. Directing grant of approval with effect from 26 March 2025, the Tribunal ruled in favour of the assessee on both the substantive question of charitable character and the procedural question of limitation.
Who is the Assessee?
The assessee is a public charitable trust constituted under a Trust Deed dated 03.12.2020, registered with the Sub-Registrar, Selaiyur, Chennai (Registration No.151 of 2000/16). It operates an institution called "Jagadguru Sri Chandrasekarendra Saraswathi Sivagama Patasala", which imparts structured education in Agama and Siva Agama scriptures while also working to preserve ancient Vedic educational traditions transmitted through oral methods and memorisation.
The stated objects of the trust, as reflected in Form No.10AB, include:
- Relief of the poor
- Education
- Advancement of any other object of general public utility
The trust had previously obtained:
- Registration under
Section 12A/12AAvide order dated 24.09.2021 (Form No.10AC, valid for AY 2022-23 to AY 2026-27) - Provisional approval under
Section 80Gon 03.08.2022 (valid up to AY 2025-26)
The Application and Its Rejection
The assessee submitted a fresh application in Form No.10AB dated 26.03.2025, seeking regular approval under clause (ii) of the first proviso to Section 80G(5) of the Income-tax Act, 1961.
The CIT(Exemptions), Chennai, rejected this application vide the impugned order dated 29.09.2025 on two distinct grounds:
Ground 1: Limitation
The CIT(E) held that the application ought to have been filed on or before 30.09.2024 under the earlier prescribed framework. Since the assessee had filed under sub-clause (ii) instead of clause (iii) of the first proviso to Section 80G(5), it was treated as time-barred.
Ground 2: Religious Character of Activities
The CIT(E) concluded that the assessee's activities—teaching Vedic and Agama texts—were religious in nature rather than charitable. Relying on the decision in Kasyapa Veda Research Foundation Vs CIT (ITAT Cochin), the authority held that Explanation 3 to Section 80G was attracted, thereby disentitling the trust from seeking approval under the provision.
Contentions Before the Tribunal
Assessee's Arguments
The Authorised Representative for the assessee submitted that: