Consistency in charitable approval: unchanged objects and past 80G approval barred a fresh denial.

Approval under section 80G was denied despite the assessee's objects remaining unchanged and earlier approval having been granted on similar terms. The Tribunal noted that registration under section 12A continued in force, the trust deed objects had not materially changed, and approval under section 80G had been available since 2001. On those facts, it applied the principle of consistency and stated that the revenue authorities should follow the earlier position. The document records that the denial of 80G approval was not sustainable and that the assessee was entitled to approval.

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Issues: Whether denial of approval under section 80G was justified when the assessee's objects were unchanged and approval had been granted earlier on similar objects.

Analysis: The Tribunal noted that registration under section 12A had already been granted on similar objects and continued to remain in force, and that approval under section 80G had been available since 2001. There was no change in the material facts or in the trust deed objects to justify a different view in the impugned year. In these circumstances, the principle of consistency required the revenue authorities to follow the earlier position.

Conclusion: The denial of approval under section 80G was not sustainable and the assessee was entitled to approval.

Ratio Decidendi: Where there is no material change in facts or objects, the revenue should maintain consistency and cannot deny charitable approval after having granted it earlier on similar terms.

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