Environmental protection and plastic waste management qualify as charitable purpose for tax registration purposes.

Preservation of environment is treated as a charitable purpose under section 2(15) of the Income-tax Act, and plastic waste management activities such as collection, segregation, treatment, processing and disposal are described as part of that environmental object. The text states that a society's bye-laws and memorandum must be read as a whole to see whether they support a public charitable purpose rather than private control, and that objections based on selected clauses, alleged restrictiveness or limited expenditure should be tested against the actual statutory environmental framework, including the Environment (Protection) Act, 1986 and the Plastic Waste Management Rules, 2016. It further notes that registration under section 12A/12AA should not be denied merely because the activities implement a regulated environmental mandate.

---

---

Issues: Whether the assessee society's objects and activities fell within the charitable purpose of preservation of environment under section 2(15) of the Income-tax Act, 1961; whether the bye-laws and memorandum showed that the society was a one-man show rather than a public charity; and whether the Commissioner was justified in refusing registration under section 12A/12AA of the Income-tax Act, 1961.

Analysis: The object of preservation of environment is expressly treated as a charitable purpose under section 2(15) of the Income-tax Act, 1961. The society's activities of collection, segregation, treatment, processing and disposal of multilayered plastic waste were held to be integral to plastic waste management and to the statutory framework under the Environment (Protection) Act, 1986 and the Plastic Waste Management Rules, 2016, including the Extended Producer Responsibility regime reflected in Schedule II of the Plastic Waste Management (Amendment) Rules, 2022. The bye-laws and memorandum were read as a whole and were found to be designed for carrying out the environmental object, not for private benefit or a one-man control. The Commissioner's objections based on selected clauses, alleged restrictiveness, and limited expenditure were rejected as inconsistent with the statutory scheme and the actual activities undertaken.

Conclusion: The assessee's objects were charitable, its activities were genuine, and the refusal of registration was unsustainable.

Final Conclusion: Registration under section 12A was directed to be granted, and the assessee's appeal succeeded.

Ratio Decidendi: An institution engaged in plastic waste management for environmental protection falls within the charitable purpose of preservation of environment, and registration cannot be denied merely because its governing structure assigns regulatory control to the statutory pollution authority or because the activities principally serve a defined class in implementing the environmental mandate.

---