Trust registration under section 12AB cannot be refused for a clerical name mismatch without allowing correction and fresh review.

A registration application under section 12AB should not be rejected solely because of an apparent mismatch in the trust's name across the PAN, Form 10AB and trust deed when the trust's existence, basic registration particulars and supporting documents are already on record. Where the discrepancy appears clerical and the applicant is not given an opportunity to explain or correct it, rejection on that ground alone is premature. The registration refusal was therefore set aside and the matter remanded for fresh consideration, with liberty to rectify the name and furnish further material on the trust's objects and activities.

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Issues: Whether rejection of registration under section 12AB of the Income-tax Act, 1961, was justified solely on account of mismatch in the name of the assessee-trust across the PAN, Form 10AB and trust documents, and whether the matter should be restored for fresh consideration.

Analysis: The record showed that the trust deed, registration particulars with the Charity Commissioner, PAN details and activities were already furnished, and the basic registration number and existence of the trust were not in dispute. The mismatch in nomenclature appeared to be an inadvertent defect. The assessee was not afforded an opportunity to explain or correct the discrepancy before the application was rejected. In these circumstances, the refusal to grant registration on that ground alone was held to be premature, and the matter was restored to the assessing authority for reconsideration with liberty to the assessee to correct the name and furnish further material regarding objects and activities.

Conclusion: The rejection of registration was set aside and the application was remanded for fresh adjudication after granting an opportunity to cure the name mismatch and to substantiate the trust's objects and activities.

Final Conclusion: The assessee obtained a limited substantive relief in the form of remand, with the registration issue left open for reconsideration on the merits after compliance opportunity.

Ratio Decidendi: A registration application under section 12AB should not be rejected merely for an apparent clerical mismatch in the trust's name when the foundational registration particulars and existence of the trust are not in dispute and no opportunity is given to rectify the defect.

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