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Issues: Whether rejection of registration under section 12AA and approval under section 80G was justified merely because the financial statements for FY 2018-19 were not furnished, and whether the appellant's objects and activities entitled it to registration and exemption.
Analysis: The appellant was a statutory welfare body constituted under the Advocates Welfare Fund Act, 2001. Its objects were held to be charitable and falling within the ambit of advancement of an object of general public utility. For registration under section 12AA, the relevant enquiry is whether the objects are charitable and whether the activities are genuine; detailed scrutiny of financial application is not required at that stage. The absence of financial statements for one year, particularly when earlier years' statements had been furnished and no adverse finding was recorded on them, was not a valid ground to refuse registration. The exemption under section 23 of the Advocates Welfare Fund Act, 2001 also supported the charitable character of the fund.
Conclusion: The rejection of registration and approval was unsustainable, and the appellant was entitled to registration under section 12AA and approval under section 80G.
Ratio Decidendi: At the registration stage, the Commissioner must examine the charitable nature of the objects and the genuineness of the activities, and cannot refuse registration solely for want of complete financial statements when the institution's objects are otherwise charitable and genuine.