80G renewal denied where institution showed only shopping complex construction and no substantial charitable activity

Renewal of approval under section 80G was refused because the institution had, over several years, only constructed a shopping complex and had not carried out substantial charitable activity within its stated objects. The record showed that the funds collected were used only for construction, and the explanation that charitable work would start after completion of the complex did not establish present engagement in charity or a public-benefit purpose. The refusal of renewal was therefore upheld and no interference was warranted.

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Issues: Whether the rejection of renewal of approval under section 80G of the Income-tax Act, 1961, was justified in view of the petitioner's activities and whether any ground for interference was made out.

Analysis: The approval had been granted earlier for a limited period, but on the record the petitioner had, for several years, only undertaken construction of a shopping complex. The materials before the Authority showed that no substantial charitable activity within the objects of the institution had been carried out, and the funds collected had been utilised only for construction. The explanation that charitable activities would begin after completion of the complex did not establish that the institution was then engaged in charitable work or that its activities were beneficial to the public in general.

Conclusion: The rejection of renewal under section 80G(5) was upheld and no interference was called for.

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