Tribunal grants appeal, renews trust's tax exemption under section 80G due to charitable objects & compliance.

The Tribunal allowed the appeal, setting aside the Director of Income-tax (Exemption)'s rejection of the trust's renewal of exemption under section 80G. It held that the trust's original object remained charitable, its registration under section 12A was valid despite changes in objects, and the trust had complied with communicating changes to the Income-tax Department. Emphasizing consistency, the Tribunal directed the renewal of approval under section 80G for the trust.

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Issues: Whether renewal of approval under section 80G could be denied on the ground that the trust's objects were amended without prior approval of the High Court and the changes were intimated late to the department.

Analysis: Approval under section 80G depends on the trust having valid registration under section 12A. The trust's section 12A registration had never been cancelled. The objects were altered under section 50A(1) of the Bombay Public Trust Act, but the amended objects remained charitable, the original charitable purpose was not deleted, and the enlargement of beneficiaries did not detract from the basic character of the trust. The requirement of intimating changes appeared only in Form No. 10A and was not a statutory condition for cancellation of registration or denial of approval. The precedent relied on by the revenue was distinguishable on facts because it concerned wholesale and material changes in objects, unlike the present case.

Conclusion: Renewal of approval under section 80G could not be refused on these grounds and the assessee was entitled to the approval.

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