Registration eligibility: refusal unsustainable where objects are charitable and activities genuine; registration must be granted.

Refusal to register a society under the income-tax registration regime was unsustainable because the registration-stage inquiry is confined to whether objects are charitable and activities genuine, not to re-open application of income or past taxability of grants. The society's memorandum showed educational and scientific objects and activities comprised government-funded, audited training, workshops and awareness programmes. Subsequent provisional and later statutory approvals for relevant years corroborated the charitable character. Prior exemption claims or accounting treatment of grants did not justify denial; registration must be granted from the application date.

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Issues: Whether the refusal by the Commissioner of Income-tax (Exemptions) to grant registration under Section 12AA of the Income-tax Act, 1961 to a society engaged in promotion of science and technology through government-funded training, workshops and awareness programmes was sustainable.

Analysis: The enquiry at the registration stage is limited to whether the objects are charitable and the activities genuine; it does not extend to re-opening the manner of application of income or past taxability of grants. The society's memorandum records educational objects and the activities consist of scientific training, workshops and awareness programmes funded and audited by government agencies. Subsequent departmental action granting provisional registration under Section 12A and later approval under Section 12AB for relevant assessment years indicates acceptance of the charitable and educational nature of activities. Prior claims of exemption under Section 10(23C)(iiiad) in earlier years or accounting treatment of grants do not justify rejection of registration under Section 12AA when objects and proposed activities are shown to be charitable.

Conclusion: The rejection of registration under Section 12AA is unsustainable; registration under Section 12AA must be granted with effect from the date of application.

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