Trust registration cannot be refused on community-benefit grounds; that bar applies at assessment, not registration.

At the registration stage for a trust, the Commissioner must examine only the objects of the trust and the genuineness of its activities. The bar relating to benefit of a particular religious community or caste applies at the assessment stage, not as a ground to refuse registration. A refusal based solely on that basis was therefore unsustainable on merits at this stage, and the matter was remanded for fresh consideration in accordance with law.

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Issues: Whether the denial of registration to the trust by invoking section 13(1)(b) and by treating the objects as confined to a particular community was sustainable at the stage of registration under section 12A/12AB.

Analysis: The Tribunal relied on earlier coordinate bench decisions and the jurisdictional High Court decision to hold that the bar under section 13(1)(b) is relevant at the stage of assessment and not at the stage of grant of registration. At the registration stage, the Commissioner is required to examine the objects of the trust and the genuineness of its activities, and cannot deny registration solely on the footing that the trust may be for the benefit of a particular religious community or caste. Since the impugned order proceeded on that impermissible basis, it could not be sustained on merits at this stage.

Conclusion: The denial of registration on the ground of section 13(1)(b) was not sustainable, and the matter was sent back for fresh consideration in accordance with law.

Ratio Decidendi: Section 13(1)(b) cannot be invoked to refuse registration under section 12A/12AB, as that provision is to be applied at the time of assessment, while registration is to be decided on the objects and genuineness of activities.

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