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2017 (11) TMI 77 - AT - Income TaxGrant of registration u/s 80G(5)(vi) rejected - no significant charitable activity has been started by the assessee trust as per its objects since 7 months came into existence - Held that:- What is a significant activity is a very subjective term and cannot be a sole basis for rejection of application. Where the assessee has various objectives, it is not necessary that the activities in furtherance of each of the objectives should be started simultaneously and at the same pace and level. It is up to the assessee to determine which all activities can be started initially and how the same can be expanded subsequently. And for that purposes, grant of approval under section 80G act as an enabler and a catalyst to encourage the prospective donors to look at the intended activities of the assessee and where they find the same to be acceptable, to provide financial support through donations/contributions. In our view, what is of relevance for the purposes of grant of approval under section 80G is whether the objectives are charitable or not and the activities, so started, howsoever insignificant it may be, are genuine activities or not and whether the same are in consonance with and in furtherance of the objectives of the assessee society. As the appellant has been duly registered under section 12AA which shows that CIT has already verified its objectives and its establishment for charitable purposes. Regarding fulfillment of additional conditions specified in clause (i) to clause (v) of section 80G(5), we find that there is no recording of satisfaction regarding non-fulfilment of any of the conditions so specified and the ld CIT(E) has summarily rejected the assessee’s application. We are accordingly setting aside the matter to the file of the ld CIT(E) to examine the matter afresh in light of above directions. Appeal of the assessee is allowed for statistical purposes.
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