The preponderance of the judicial opinion of all the High Court including this Court is that at the time of registration under Section 12AA of the Income Tax Act, which is necessary for claiming exemption under Section 11 and 12 of the Act, the Commissioner of Income Tax is not required to look into the activities, where such activities have not or are in the process of its initiation. Where a trust, set up to achieve its objects of establishing educational institution, is in the process of establishing such institutions, and receives donations, the registration under Section 12AA cannot be refused, on the ground that the Trust has not yet commenced the charitable or religious activity.
The corporate advisors play a very vital and the core role for the companies in respect of various advisory activities including representation before authorities. The corporate advisors generally are chartered accountants, company secretaries, cost and management accountants, advocates, tax practitioners, etc.