Assessee was a Centrally Funded Institution of National Importance set up by Government of India in 2015. Assessee applied for provisional registration in Form 10A and said provisional registration was granted in Form 10AC under sub-clause (A) of clause (iv) of first proviso to clause (23C) of section 10. Thereafter, assessee applied for final registration under clause (iii) of first proviso to clause (23C) of section 10. Commissioner (E) denied approval on ground that provisional approval could not have been granted to assessee as assessee had already commenced its activities in 2015 and, thus, provisional approval being bad in law was rejected. On appeal the Tribunal held that   since approval was refused only on account of technical mistake on part of assessee, who inadvertently had chosen wrong sub-section while moving application for approval, Commissioner (E) was to be directed to grant approval to assessee as if it was an old Institute, which came into existence prior to 1-4-2021 and was entitled to get approval under clause (iii) of first proviso to clause (23C) of section 10.