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7. Further, the Delhi Benches of the Tribunal in the case of Sai Ashish Charitable Trust vs DIT (E) in ITA No.5591/Del/012 held that the DIT (E) has not pointed out any defect or doubt about the charitable objects of the assessee trust. From the impugned order, we clearly observe that the DIT(E) has rejected the application of the assessee trust for grant of registration u/s.12A of the Act by holding that in absence of any charitable activity, the genuineness of the activities cannot be held to be established. At the same time, we observe that as per ratio of the decision of Hon'ble Jurisdictional High Court in the case of DIT(E) vs Foundation of Ophthalmic and Optometry Research Education Centre, registration u/s.12A is not dependent on commencement of charitable activity. The registration granting authority is not required to examine the question whether the trust has actually commenced and carried on its charitable activities. We also take cognizance of decision of Hon'ble High Court of Allahabad in the case of R.S.Bajaj Society, as relied by the assessee, wherein, their Lordships held that at the time of registration, only genuineness of the objects was to be tested and not the activities which were not commenced at that time.

11. Therefore, the object of Section 12AA of the Act, is to examine the genuineness of the objects of the Trust, but not the income of the Trust for charitable or religious purposes. The stage for application of income is yet to arrive i.e. when such Trust or Institution files its return. Therefore, we find that the judgments referred to by the learned counsel for the appellant are not applicable to the facts of the present case arising out of the question of registration of the Trust and not of assessment.