Denial of 80G Approval for Non-Commencement of Activities and Expiry of Registration: ITAT Remits Matter to CIT(E)

The Income Tax Appellate Tribunal (ITAT) addressed the denial of approval under Section 80G of the Income Tax Act to a trust due to non-commencement of charitable activities and expiry of registration under Section 12AB. The tribunal emphasized that such denial must be based on a factual assessment of genuine charitable intent and operational progress rather than mere technical lapses. It noted that premature rejection without providing sufficient opportunity for explanation contravenes principles of natural justice. The case was remanded to the Commissioner of Income Tax (Exemption) for fresh consideration, underscoring that procedural delays or lack of activity initiation cannot automatically negate charitable purpose. The order reinforces fairness and transparency in granting 80G benefits essential for donor confidence and trust credibility.