80G approval denied where unexplained donations showed activities were not confined to stated educational objects.

Denial of approval under section 80G(5) was upheld because the trust failed to explain donations made to other trusts and a relief fund, and produced no supporting material showing that the payments were connected to its charitable or educational objects. On the evidence, the authority and the Tribunal accepted that the activities were not confined to the claimed educational purpose, so the approval could not be granted.

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Issues: Whether the denial of approval under section 80G(5) of the Income-tax Act, 1961 was justified on the ground that the trust had made donations which were treated as non-educational and inconsistent with its stated objects.

Analysis: The assessee did not satisfactorily explain the nature of the donations made to other trusts and the relief fund, nor did it place supporting material before the authority or the Tribunal to show that those payments were connected with its charitable or educational objects. In the absence of evidence, the conclusion that the activities were not confined to the claimed educational purpose was accepted.

Conclusion: The denial of approval under section 80G(5) was upheld and the assessee's appeal failed.

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