Registration u/s 12A cannot be denied merely on the count that no substantial activities have been carried out:

CIT rejected assessee-trust’s application for registration u/s 12A since he was not satisfied with the activities of the assessee and was of the opinion that no substantial charitable activities were carried out. ITAT quashed the said order and gave a direction to grant registration to the assessee u/s 12A. On Revenue’s appeal, Hon’ble High Court observed that the main object of the assessee was to promote, establish, run, support, maintain and advance the cause of education, to grant aid, or other assistance to all types of educational institutions including schools, colleges, universities and other institutions for the benefit of students. Revenue had neither doubted nor disputed the object and purpose of the assessee. Also it was first year after the establishment of the assessee-trust. Assessee was registered u/s 25 of the Companies Act. Total donation received by the assessee was merely Rs.7,103/- out of which scholarship was given to the tune of Rs.4,000/- approx. Hon’ble High Court thus held that ITAT was right in holding that looking to the magnitude of income during the under consideration, charitable activities carried out cannot be considered to be of low magnitude. ITAT had rightly directed to grant registration to the assessee u/s 12A. Accordingly, Hon’ble High Court upheld the order of ITAT and dismissed the Revenue’s appeal.

[CIT vs. Satvara Education Foundation – Tax Appeal No.907 of 2013]