On appeal by the Revenue allowing the appeal the Court held that   neither the order of refusal of the certificate under section 80G(5B) nor the subsequent order of the Tribunal dealt with essential facts as to the quantum of receipts and the expenditure incurred. While the assessee claimed to continue to hold exemption under section 12AA of the Act, never the less, for the benefit under section 80G(5B), the requirements of that provision have to be satisfied separately. In view of the fact that the Commissioner’s order as well as the order of the Tribunal were bereft of any factual details as to the nature of activities which the assessee carried on and the accounts involved, the matter required to be considered afresh by the Commissioner(E) in the light of the contentions to be urged on behalf of the assessee. It was open to the assessee to rely on the fact that it was recipient of the benefit under section 80G(5B) for subsequent periods (Assessment years 2022-23 to 2026-27).