Trust granted registration under IT Act despite infancy status and no immediate charitable activities.

The ITAT allowed the appeal filed by the trust against the denial of registration under sections 12A and 12AA of the IT Act. Despite the trust being at an initial stage with no immediate charitable activities, the ITAT considered its alignment with charitable purposes, infancy status, and precedents supporting registration for trusts in similar situations. The Inspector's report did not raise any adverse findings, leading to the direction for the DIT (Exemption) to grant registration to the trust.

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Issues:
1. Denial of registration under section 12A of the IT Act due to noncompliance with section 12AA(1).
2. Verification of activities of the assessee trust by the Inspector.
3. Disagreement on the conformity of the trust's activities with its stated objects.
4. Argument of the trust being at an infant stage and deserving registration.
5. Comparison with previous judgments allowing registration for similar trusts.
6. Examination of the trust's objects and activities to determine eligibility for registration.

Issue 1: Denial of Registration
The appeal was filed by the assessee trust against the order of the DIT (Exemption) denying registration under section 12A of the IT Act due to noncompliance with section 12AA(1). The trust had applied for registration on 25-01-2012 but failed to provide complete details of its activities and bank account, leading to the denial.

Issue 2: Verification by Inspector
The Inspector's report revealed that the trust's premises showed no visible activities related to its charitable objects. The Inspector noted the absence of trustees and directed to meet a staff member who mentioned the charitable activities of the Lalbhai Group. The report formed the basis for the DIT (Exemption) to conclude that the trust's activities did not align with its stated objects.

Issue 3: Conformity of Activities
The DIT (Exemption) refused registration, citing non-conformity of the trust's activities with its objects related to education, medical relief, and cultural advancement. The trust argued that it was at an initial stage and deserved registration based on its charitable intentions as per the trust deed.

Issue 4: Trust at Infant Stage
The trust contended that being at an infant stage, it should be granted registration despite the lack of immediate charitable activities. The trust deed outlined various charitable purposes, indicating its intent to engage in charitable work once operational.

Issue 5: Comparison with Previous Judgments
The ITAT referred to previous judgments where trusts in similar situations were granted registration despite not having commenced charitable activities immediately. The decisions emphasized examining the trust's objects and genuineness rather than its immediate activities.

Issue 6: Examination of Trust's Objects
After reviewing the trust's objects and the Inspector's report, the ITAT found no adverse inference to refuse registration. Citing the trust's infancy, alignment with charitable purposes, and precedents, the ITAT directed the DIT (Exemption) to grant registration under sections 12A and 12AA of the Act.

In conclusion, the ITAT allowed the appeal, considering the trust's infancy, alignment with charitable objects, and the precedents supporting registration for trusts at initial stages.

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