The Court held that non-disposal of an application for registration within six months does not lead to a deemed grant of registration, as there is no deeming fiction in law under S. 12AA(2). Relying on Harshit Foundation Sehmalpur v. CIT (2022) 328 CTR  609(SC) and CIT v.  Muzafar Nagar Development Authority (2015) 275 CTR  233 (FB)  (All)(HC), it was clarified that the law declared by the Supreme Court is binding under Art. 141 and that both  CIT v. Society for Promotion of Education  Adventures Sport  (2016) 282 CTR 207/ 382 ITR 6 (SC(and CIT v. Harshit Foundation Sehmalpur (2022) 139 taxmann.com 55 (All)(HC)  are reconcilable. Accordingly, Tribunal’s order granting deemed registration was set aside. Section 12AA(2) does not recognise any deeming fiction   that  an application for registration  is deemed to be granted, if it is not disposed of within six months.  Appeal of revenue was allowed.