The High Court held
as under:
1) The object of Section 12AA is to examine the
genuineness of the objects of the Trust and though while examining genuineness,
the income as well as resources of the Trust may be taken into consideration
but any suspicion as to these facts cannot be the sole criteria for rejecting
an application under Section 12A;
2) Merely because a
trustee was a life-long member of a trust, same could not itself raise an
inference that trust was not charitable. Therefore, Tribunal was justified in
directing registration of assessee as charitable trust. – CIT v. Baba Kartar Singh Dukki Educational
Trust [2014] 42 taxmann.com
17 (Punjab & Haryana)