Assessee has  already registered/approved under section 80G(5) as a charitable institution since 2008. However, post-amendment brought into relevant provisions of section 80G vide Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 with effect from 1-4-2021, assessee applied for provisional approval under clause (iv) to first proviso to section 80G(5). Assessee was granted same for a period from 28-5-2021 to assessment year 2024-25. The assessee applied for final approval under clause (iii) to first proviso to section 80G(5).Commissioner (E), however, rejected application on the ground that the  assessee had already commenced its activities since long even prior to grant of provisional registration, and further, since time period for making application mentioned in clause (iii) to first proviso to section 80G(5) had already expired on 30-9-2022 vide CBDT Circular No. 18/2022, therefore, assessee could not be granted final registration under section 80G(5). On appeal the Tribunal following the judgement in  Tomorrow’s Foundation v. CIT (E)( 2024) 160 taxmann.com 174 ( Kol)( Trib) held that  Final approval cannot be rejected on the ground that  institution had already commenced its activities even prior to grant of provisional registration.