Registration under Section 12AA does not confer Section 80G benefits; 80G conditions must be satisfied independently year by year.

Registration under Section 12AA does not automatically entitle an entity to donor-deduction benefits under Section 80G; entitlement under 80G depends on independent satisfaction of the statutory conditions in that provision, assessed with reference to receipts and expenditures relevant to the assessment year. The established principle that 12AA registration and 80G eligibility are distinct is applied, permitting review or denial of 80G benefits where non-compliance with Section 80G conditions is shown. The Court disposed of the appeal in favour of the assessee while reaffirming that 80G entitlement must be established year wise on statutory criteria.

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Issues: (i) Whether registration under Section 12AA of the Income-tax Act, 1961 automatically entitles an entity to exemption under Section 80G of the Income-tax Act, 1961 for assessment years, or whether the requirements of Section 80G must be satisfied independently for each assessment year.

Analysis: The question concerns the relationship between registration under the charitable registration provision and entitlement to donor-deduction exemption. The legal framework requires examining the specific statutory requirements of Section 80G and the distinct provision for registration under Section 12AA. Prior precedent establishes that eligibility for the benefit under Section 80G(5B) depends on satisfaction of the conditions specified in that provision, including consideration of receipts and expenditure relevant to the assessment year, and is not conferred automatically by registration under Section 12AA. Applying that principle to the present proceedings, the factual position shows that the respondent has been enjoying 80G benefit pursuant to earlier orders; however, entitlement under Section 80G remains subject to independent satisfaction of its statutory requirements and potential review where non-compliance is alleged.

Conclusion: Registration under Section 12AA of the Income-tax Act, 1961 does not automatically confer entitlement to exemption under Section 80G of the Income-tax Act, 1961; the requirements of Section 80G must be satisfied independently for the benefit to apply. This conclusion is in favour of the assessee on the present appeal as disposed of by the Court.

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