Section 12AA registration depends on charitable objects and genuine activities, not exemption eligibility or collateral objections.

At the registration stage under section 12AA, inquiry is confined to the trust's objects and the genuineness of its activities, not to whether income will ultimately qualify for exemption under sections 11 and 12. The trust's educational objects and operation of a school and college supported charitable activity, and no material showed the activities were not genuine. Objections based on alleged section 13 violations, the trust's structure as a society, and the rule against perpetuity were treated as outside the limited scope of registration proceedings. The refusal of registration was therefore unsustainable, and registration under section 12AA was allowed.

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Issues: Whether the assessee trust was entitled to registration under section 12AA of the Income-tax Act, 1961, in the light of the Commissioner's objections regarding the alleged non-genuineness of activities, the trustees' arrangement, and the trust's form.

Analysis: At the stage of registration under section 12AA, the inquiry is confined to the objects of the trust and the genuineness of its activities. The question whether the trust's income ultimately qualifies for exemption under sections 11 and 12 is a matter for assessment and not for refusal of registration. The trust's educational objects and its running of school and college showed charitable activity, and no material established that the activities were not genuine. The objections based on alleged violations of section 13 and the structure of the trust as a society were held irrelevant to the limited scope of registration proceedings. The rule against perpetuity was also held inapplicable to a public charitable trust.

Conclusion: The refusal of registration was unsustainable, and the trust was held entitled to registration under section 12AA.

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