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Section 80G does not contemplate different yardstick and different parameters being applied to different trusts having similar objects and similar purpose Section 80G, read with section 2(15), of the Income-tax Act, 1961 - Deductions - Donation to certain funds, charitable institutions, etc. - Whether section 80G, does not contemplate different yardstick and different parameters being applied to different trusts having similar objects and similar purpose - Held, yes FACTS Tax Practitioners Benevolent Fund, the petitioner herein, was a public charitable trust registered under the Bombay Public Trust Act, 1950. The objects of the said trust were (A) to provide financial assistance for maintenance, education or any other similar purpose to necessitous person being (i) persons who were or had been in practice of taxation, or (ii) wives and children of persons who were or had been in practice of taxation, or (iii) widows and children of deceased persons who had been in practice of taxation, or (iv) relatives or others who were dependent for support on a person who had been in practice of taxation and who had died without leaving a widow or child; or (B) do any other act for the advancement of general public utility without distinction of sex, colour, caste, creed or religion, and other charitable objects. The said trust was also registered with Income-tax Department under section 12A. The petitioner-trust applied for exemption in the prescribed form under section 80G. The Commissioner, Nagpur, however, rejected the petitioner's application for exemption under section 80G observing that none of the objects at (A) was charitable in nature inasmuch as the trust was meant for the benefit of a specific group of people, i.e. Tax Practitioners and their relatives, and the objects stated at (B) were vague. On writ, the petitioner contended, inter alia, that exemption under section 80G had been granted to another public charitable trust, viz., the Char- tered Accountants' Benevolent Fund, having identical objects for the benefit of necessitous person, Chartered Accountants, or their widows, children and dependents by the Director of Income-tax (Exemption), New Delhi. HELD…

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