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Issues: Whether, while considering registration of a charitable trust at the commencement stage, the revenue authority could cancel or refuse registration on the ground that the trust had not yet carried out charitable activities, and whether the Tribunal was correct in allowing exemption-related relief on the basis of the trust deed recitals.
Analysis: The trust's objects were accepted as religious and charitable in nature. At the stage of registration, the authority's inquiry was confined to examining whether the stated objects were charitable. Actual charitable activities had not yet commenced, and that circumstance did not justify cancellation of the registration on the ground adopted by the revenue.
Conclusion: The Tribunal's view was upheld and the issue was answered against the revenue.