CIT (E) rejected the application on the grounds of non-commencement of activities. On appeal, the Tribunal held that non-commencement of activities at the time of filing the application or at the time of passing the order for grant of registration under section 12AB cannot be the sole reason for denial of registration without considering the proposed activities of the assessee trust.  Matter remanded to the file of CIT E) to decide in accordance with law. (AY. 2025-26)