Section 12AA registration supports 80G approval, and no substantial question of law arose in the tax appeal.

Subsisting registration under Section 12AA was treated as sufficient basis for approval under Section 80G(5), and the authority could not refuse approval merely because the trust had religious objects or because a fresh enquiry into charitable character was sought. The Court also treated the issue as covered by prior authority and found no debatable question warranting interference under Section 260A. The Revenue's challenge therefore failed, and the tax appeal was terminated at the threshold.

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Issues: (i) Whether registration under Section 12AA of the Income-tax Act, 1961 entitled the assessee to approval under Section 80G(5) of the Income-tax Act, 1961. (ii) Whether any substantial question of law arose in the Revenue's appeal under Section 260A of the Income-tax Act, 1961.

Issue (i): Whether registration under Section 12AA of the Income-tax Act, 1961 entitled the assessee to approval under Section 80G(5) of the Income-tax Act, 1961.

Analysis: The settled law applied by the Court was that once registration under Section 12AA of the Income-tax Act, 1961 is granted and continues to operate, the authority is not justified in denying approval under Section 80G(5) merely on the ground that the trust is also connected with religious objects or that its activities require a fresh enquiry into charitable character.

Conclusion: The assessee was held entitled to approval under Section 80G(5) of the Income-tax Act, 1961 on the basis of its subsisting registration under Section 12AA of the Income-tax Act, 1961.

Issue (ii): Whether any substantial question of law arose in the Revenue's appeal under Section 260A of the Income-tax Act, 1961.

Analysis: The Court applied the binding position that the legal issue stood covered by prior authority and that, in the facts of the case, no debatable question survived for consideration in the tax appeal.

Conclusion: No substantial question of law was held to arise.

Final Conclusion: The challenge to the order granting approval failed, and the Revenue's tax appeal was terminated at the threshold.

Ratio Decidendi: Where registration under Section 12AA of the Income-tax Act, 1961 is in force, approval under Section 80G(5) cannot be denied by reopening the question of charitable entitlement, and no substantial question of law arises against such a covered determination.

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