Dismissing the appeal of the revenue the Court held that ; Proviso to S. 12A(2) inserted with effect from 1-10-2014 stating that registration will have effect prior years in respect of which assessment proceeding pending .Proviso is declaratory and will have and has retrospective effect . Appeal is a continuation of the original proceedings and assessment proceedings pending before an appellate authority should be deemed to be assessment proceedings pending before the Assessing Officer.