The assessee trust, registered u/s 12A, received CSR funds from group companies for specified CSR projects. The AO reopened the assessments and treated unspent CSR receipts as taxable income, also denying exemption due to non-filing of Form 10 within time. CIT(A) affirmed the order of the Assessing Officer . On appeal The Tribunal observed that these funds were restricted in use, subject to quarterly reporting, donor supervision, and even refund if unutilised, and therefore resembled tied-up grants rather than voluntary contributions. For AY 2018-19, Form 10 was filed for the first time before the Tribunal with an application for condonation of delay of about 2500 days. The Tribunal held that although Form 10 is mandatory, the lapse was bona fide and not deliberate. Relying on settled principles that substantial justice must prevail over procedural technicalities, the Tribunal directed the assessee to seek CBDT condonation and remitted the matter to the AO for fresh consideration.   The Honourable Tribunal relied on following case laws for condonation of delay , Pala Marketing Co-operative Society Ltd. v. UOI (2009)311 ITR 177 (Ker) HC)  Sitaldas K. Motwani vs. DGIT reported in [2010] 323 ITR 223 (Bom)(HC) , Sanchit Software & Solutions (P.) Ltd. v. CIT (2012)349 ITR 404 (Bom HC),   Collector, Land Acquisition v. Mst. Katiji (1987) 167 ITR 471 (SC), People Education & Economic Development Society v. ITO (2006) 100 ITD 87 (TM)(Chennai ITAT) CIT v. K.S.P. Shanmugavel Nadai 1985 ) 153 ITR 596) (Mad HC)  Bajaj Hindusthan Ltd. v. Jt. CIT (2005) 92 ITD 411 / 277 ITR 1 (Mum)( Trib )     Sandhya Rani Sarkar v. Sudha Rani Debi AIR 1978 SC 537) (AY.  2017-18 & 2018-19 )( ITA Nos.: 6557 & 6558/Mum/2025 dt  29.12.2025 )