Held that the assessee was allotted land by letter dated December 23, 2022 and applied for regular approval under section 80G(5) on April 23, 2023. The activities of the assessee-trust in the real sense started from the day when the beneficiary actually got benefits of the activities carried out by the institution in furtherance of its objects and mere receipt of donation was not a commencement of charitable activities. At the worst for the purpose of counting six months the date of allotment of land was to be taken. The Tribunal restored all the appeals to the Commissioner (E) for reconsideration of their applications under section 80G(5) and to allow them approval under section 80G(5) in accordance with law. That the delay in filing application for regular approval under section 80G(5) of 123 days is  condoned. (AY. 2023-24)