The assessee is a non-profit organization, incorporated u/s. 8 of the Companies Act, 2013 .The object of the company is to promote Indian heritage art such as Indian Classical music, Organize regular concerts and performances by renowned and emerging Indian classical musicians, Establish or support training school or institute to teach Indian classical music to students of all ages and skill levels, to Indian classical musicians to cover the costs of performance, travel, and recording, Organize festivals and conferences that bring together Indian classical musicians and scholars from around the world.  The assessee was initially granted provisional registration u/s. 12AB as well as u/s 80G of the Act on 29-01-2024 from AYs. 2024-25 to 2026-27.  The assessee filed prescribed applications seeking permanent registration u/s.12AB and 80G of the Act. Both the applications filed by the assessee were rejected by the Ld. CIT(E) on the ground that the objects of the assessee leave room for any future potential endeavour that may result in incurring expenditure outside India, which is in violation of S.11 of the Income tax Act,  secondly  the  activities claimed to have been done are not justified by the expenses incurred by the assessee. On appeal the  Tribunal held that the objects of the trust may contain clauses, which may enable a charitable trust or institution to apply its income for activities carried outside India , however   such objects, if any, would  not enable the Ld CIT(E) to deny registration u/s 12AB of the Act  Followed , Sarbat The Bhala Gurmat Mission Charitable Trust v. CIT(E) [2021] 127 taxmann.com 816 /189 ITD 353 (Chd( Trib. ). The Tribunal also held that provision of Section. 12AA is identical with the provisions of section. 12AB of the Act . Accordingly  the   application of income of a charitable trust or institution outside India for carrying out its objects will not fall under any of the categories of “specified violation” as mentioned in the Explanation to S.12AB(4) of the Act . Honourable  Tribunal  following the ratio in    MK Nambyar SAARF Law Charitable Trust v. UOI ( 2004) 269 ITR 556/ 140 Taxman 616 ( Delhi)( HC) held that   section 12AB does not refer the activities carried on  in India or out  side India   . Order of CIT( E) denying the exemption and denial of exemption under Section 8OG   is set aside . As regards the genuineness  of the activities is concerned , the Tribunal admitted  the additional  evidence and remanded to the CIT( E) to examine the issue in accordance with law  .  (ITA No. 743 / Mum/2025 / 744/Mum/2025  dt . 2-4 -2025 )