80G approval and charitable genuineness: rejection set aside where evidence of activities and corpus was not properly examined

Approval under section 80G was held unsustainable where the assessee was already registered under section 12A and had filed material showing charitable activities, including donations, scholarships and charitable assistance. The record also explained the share-donation corpus relied on in support of the application. Because the authority did not properly examine this evidence, its reasons for rejection were found to be contrary to the record. On the available material, the genuineness of the activities was treated as satisfied, and approval under section 80G was directed to be granted.

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Issues: Whether rejection of approval under section 80G was justified when the assessee had produced material to show its charitable activities and the share-donation corpus explained in support of the application.

Analysis: The material on record showed that the assessee was already registered under section 12A and was carrying out charitable activities. The documents filed before the authority included details of donations, scholarships, charitable assistance, and the share-donation transaction said to form part of the corpus. The reasons recorded for rejection were found to be contrary to the record because the evidentiary material supporting both the activities and the source of corpus had not been properly examined. On the available record, the requirement of genuineness of activities was treated as satisfied.

Conclusion: The rejection of approval under section 80G was not sustainable and approval was directed to be granted in favour of the assessee.

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