Dismissing the appeal of the revenue the Court held that ,the registration under S. 12A should be deemed to have taken effect after six months from the date of presentation of the application, i. e., March 18, 2000. Admittedly, the application under S. 12A was made on September 17, 1999 and the order on such application had been passed beyond a period of six months, i.e., on October 30, 2001. The registration had already been granted in favour of the assessee under S. 12A by an order dated June 3, 2003. However, mere grant of registration to the assessee would not result in the grant of benefit to the assessee ipso facto under S. 11 and 12 and if any regular assessment was pending, it should be completed. ( Followed ,CIT v. Society for Promon of Edn. (Allahabad) (2016) 382 ITR 6 / 238 Taxman 330 (SC)
DIT(E) v. St. Ann’s Education Society (2020) 425 ITR 642 / 315 CTR 596/ 272 Taxman 251 ( Karn) (HC)
S. 12A : Registration –Trust or institution- Order granting o rejecting of application to be passed within 6 Months — Application Filed On 17-9-1999 decided on 31-10-2001 beyond period of six months —Registration shall be deemed to have taken effect after six months from date of filing application — Grant of registration does not ipso facto entitle to exemption . [ S.2(15) 11, 12A ]