Where the assessee-trust was already registered u/s 12A, the refusal of exemption u/s 80G on the ground that the trust donated funds to other trusts was held unsustainable. The High Court noted that the assessee had substantial gross receipts and had made donations to another trust also registered u/s 12A and eligible for s. 80G approval; mere suspicion on such donations ancillary to the trust’s objects could not justify denial. The impugned order declining recognition under s. 80G(5) was therefore set aside.