D K Ajmera Foundation Trust v. PCIT (2022) 197 ITD 784/ (2023)224 TTJ 761 (Mum.) (Trib.)

S. 12AB : Procedure for fresh registration-Condition for granting registration-Granting registration for three years is held to be not valid-Direction issued for grant of registration for five years-Matter remanded. [S. 12A(1)(ac)(i), 12AB(1)(c) Form No. 10AC]

Whether section 12AB(1)(a) does not allow any conditions to be imposed for granting registration-Held, yes-Held that provisional registration under section 12AB(1)(c) is to be granted for 3 years to charitable institutions which are yet to start their activities and which apply under section 12A(1)(ac)(iv). However  where existing trust registered under section 12A applied for registration under section 12A(1)(ac)(i), it was to be granted registration under section 12AB(1)(a) for 5 years and not provisional registration for 3 years under section 12AB(1)(c). Accordingly the  designated authority under section 12AB was to be directed to de novo consider application of assessee-trust under section 12A(1)(ac)(i) and grant registration as per law.Matter remanded (AY. 2022-23)