Dismissing the appeal of the revenue the Court held that the view that the assessee was directly hit by the proviso to S.  2(15) of the Act may lead to denial of exemption to the assessee in the assessment proceeding for the relevant assessment year but could not be a ground for cancellation of registration under S. 12AA(3) of the Act . The competent authority must be satisfied that the activities of the trust are not genuine or that the activities are not being carried out in accordance with the objects of the trust or the institution. Such satisfaction must be recorded as a matter of fact on the basis of specific materials on record. The cancellation of registration was not valid.( AY.2009-10)