By the Court.—We have heard Shri Rahul Agarwal for the appellant. Shri Govind Krishna appears for the Commissioner, Income Tax.

2. The appeal was admitted on 11.12.2012 on the following substantial questions of law. :

“(a) Whether it is essential for a trust to commence charitable/educational activity before it can be considered eligible for registration under Section 12 AA of the Income Tax Act and the order of the Tribunal below is legally sustainable?

(b) Whether the findings of the Tribunal that the appellant had failed to provide any explanation regarding the use of logo of a family concern in its prospectus and rebut the finding of the Commissioner of Income Tax-II, Agra is perverse and liable to be set aside?

(c) Whether in any view of the matter, the order of the Tribunal below is legally not justifiable and the application for registration under Section 12 AA and for approval under Section 80 G move by the appellant deserves to be allowed?”

3. Briefly stated the facts giving rise to this appeal are that Hardayal Charitable & Educational Trust, 318, Shambhu Nagar, Shikohabad, was established by a Trust deed executed on 17.11.2008. It was registered with Sub-Registr