Dismissing the appeal of the Revenue the Court held that the Tribunal was justified in granting approval under section 80G(5) to the assessee-charitable trust. The Tribunal had found that the Commissioner did not raise any objection with regard to the genuineness of the assessee’s activities, that his objection was only with the volume of activities carried out by the assessee on the ground that in eight months no significant charitable activities had been carried out by it. On the facts the Tribunal had held that as per rule 11AA(5), the Commissioner could reject the application for approval under section 80G, after recording the reasons for such rejection in writing, if he was satisfied that one or more conditions laid down in clauses (i) to (v) of sub-section (5) of section 80G were not fulfilled, that since the Commissioner had not recorded any reason that the assessee had failed to fulfill the statutory conditions, his order rejecting the application for approval could not be affirmed and that therefore, the Commissioner was directed to grant approval under section 80G(5). No substantial l question of law.