Assessee applied for approval under section 80G(5)(vi) of the Act. CIT (E) rejected application, citing a deficiency in significant charitable activities as per examination of charity accounts. On appeal, Tribunal held that lack of significant charitable activities did not invalidate genuineness of trust’s activities. It clarified that there’s no specific timeframe mandated for carrying out charitable activities under section 80G(5)(vi) and as Commissioner didn’t provide reasons for rejecting application based on specified conditions, Tribunal directed Commissioner to grant approval under section 80G(5) of the Act. High Court upheld order of Tribunal. SLP of Revenue is dismissed. Leaving the question of law open .