Held that the findings given by the Director (E) as well as by the Tribunal were not in any manner erroneous or contrary to law. As would be seen from the order passed by the Director (E) as well as the order passed by the Tribunal, it clearly reflected that the assessee had taken a contradictory stand justifying the delay. The assessee, on the one hand, had submitted that because of the rush of work on account of frequent expansion of the educational society, they were not able to apply for registration under section 12A. At the same time, they also took a stand that since they had an exemption under section 10(23C)(iiiad), they were not required to seek another registration under section 12A and once they had crossed the limit that was prescribed under section 10(23C)(iiiad). Order of Tribunal affirmed. (AY. 2004-05)