Held that according to section 12A(2) of the Act, if any assessment proceeding was pending during the pendency of registration under section 12AA of the Act, then the registration granted shall be applicable to the pending assessment proceedings. The Central Board of Direct Taxes Circular No. 1 of 2015(2015) 371 ITR 22 (St) explained section 12A(2) of the Act. The proviso to section 12A(2) was introduced to remove hardship caused to genuine trusts. It had not been alleged by the Department that the assessee’s activities or objects were not charitable in nature, rather it was an admitted fact that the assessee’s objects and activities were charitable in nature. The Commissioner (Exemptions) after examining the objects and activities of the assessee-trust, had granted registration under section 12AA of the Act to the assessee-trust. The order under section 143(1) was issued on January 2, 2018 and registration under section 12AA of the Act was granted on October 20, 2016, which meant that at the time of issue of the order under section 143(1), the assessee already had registration under section 12AA of the Act. Therefore, in terms of the proviso to section 12A(2) of the Act, the assessee is  eligible for deduction under section 11 of the Act for the assessment year 2016-17 as it had received registration under section 12AA of the Act before the order under section 143(1) for the assessment year 2016-17 was passed. Tribunal also held that only the profit can be taxed and not the entire receipt if benefit of section 11 is to be denied. Therefore, the CPC has erred in taxing entire receipt of the assessee under section 143(1) of the Act.(AY. 2016-17)