The assessee, an educational society, sought condonation of delay and grant of registration under section 12A with effect from 15-5-1989. The grounds urged were (i) inadvertence on the part of its accountant, and (ii) that its gross receipts exceeded Rs. 1 crore only from AY 2003-04 and, therefore, it did not consider it necessary to apply earlier. The Court held that both grounds were self-contradictory. If there was bona fide ignorance, the second ground would not arise; conversely, if the assessee consciously did not apply because its income was below Rs. 1 crore, the plea of inadvertence was untenable and an afterthought. The fact that the assessee had been claiming exemption under section 10(23C)(iiiad) from the beginning demonstrated its awareness of statutory requirements. Despite such awareness, it deliberately chose not to seek registration under section 12A. In the absence of cogent and justifiable reasons explaining the inordinate delay, the authorities were justified in refusing retrospective registration. The findings of the Director of Income-tax (Exemptions) and the Tribunal were neither erroneous nor contrary to law.