Prima facie scrutiny governs charitable registration; incomplete documents and unproved community-benefit allegations cannot justify refusal.

Charitable registration under section 12AB and approval under section 80G(5) must be decided on a prima facie review of the objects and genuineness of activities at the threshold stage. The Tribunal held that photographs, bills, activity details and expenditure particulars were sufficient to show prima facie charitable activity, and that incomplete supporting documents alone could not justify rejection. An allegation that the trust benefited a particular religious community also required a concrete adverse finding, which was absent. The rejection of registration and approval was therefore unsustainable, and relief was held to be available.

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Issues: Whether the assessee was entitled to regular registration under section 12AB and regular approval under section 80G(5) when its objects were charitable and its activities were prima facie supported by documents, notwithstanding alleged deficiencies in supporting material and an unsubstantiated objection of benefit to a particular community.

Analysis: At the stage of grant of registration and approval, the enquiry is confined to the charitable nature of the objects and the prima facie genuineness of activities. A conclusive examination of every transaction, beneficiary detail, or supporting document is not required at that threshold stage. The material placed on record, including photographs, bills, activity details, and expenditure particulars, was sufficient to show prima facie charitable activity. Mere absence of some documents or incomplete supporting evidence could not by itself justify rejection. The objection that the trust benefitted a particular religious community also required a concrete finding that the trust was established or operated solely for such restricted benefit, which was not established on the record.

Conclusion: The rejection of registration and approval was unsustainable, and the assessee was entitled to registration under section 12AB and approval under section 80G(5).

Final Conclusion: The Tribunal held that charitable registration and exemption approval cannot be refused at the threshold on mere technical deficiencies or unsupported allegations when the objects are charitable and the activities are prima facie genuine.

Ratio Decidendi: For granting registration and approval to a charitable institution, the authority must limit itself to a prima facie scrutiny of the objects and genuineness of activities and cannot deny relief on the basis of incomplete documentation or unproved allegations without a concrete adverse finding.

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