The Tribunal, in its order, noted that the Commissioner of Income Tax (CIT) had not produced any concrete evidence to demonstrate that the assessee’s activities were wholly or substantially religious. Since the trust was already registered under Section 12A and no evidence was produced to establish a religious character, the High Court upheld the Tribunal’s decision. CIT has not brought any specific instances suggesting that the activities of the assessee are religious in nature particularly when most of the objects are apparently religious? CIT has not brought any specific instances suggesting that the activities of the assessee are religious in nature. CIT and direct him to grant the registration certificate under section 80G of the Act.