The assessee, Mohanji Bharat Welfare Foundation, a charitable company registered under the Companies Act, was granted provisional registration under section 80G on 09.02.2022, valid up to A.Y. 2024–25. The assessee filed Form No. 10AB for regular registration on 03.08.2024, i.e., 33 days after the extended due date of 30.06.2024. The CIT(E) rejected the application as time-barred and further observed that certain clauses in the Memorandum of Association permitted application of funds outside India, allegedly violating section 11(1)(c). The assessee submitted that it was a small organisation without a full-time accountant and the delay occurred due to technical glitches on the income-tax portal. It also produced an affidavit and board resolution showing that steps had been initiated to amend the Memorandum to remove the offending clauses. The Tribunal observed that the assessee had filed Form No. 10AB before the end of A.Y. 2024–25 and, even assuming a delay, sufficient cause was shown. Relying on Swachh Vapi Mission Trust v. CIT(E) (2024) 160 taxmann.com 657 (Surat)(Trib.) and Saaksh Foundation v. CIT(E) (2024) 162 taxmann.com 474 (Mum)(Trib.), it was held that technical difficulties constitute reasonable cause and delay can be condoned to advance substantial justice. The Tribunal noted that it is the final fact-finding authority under section 254(1) and has power to condone such delay. After insertion of the proviso to section 12A(1)(ac)(iii) by the Finance (No. 2) Act, 2024 w.e.f. 01.10.2024, even the CIT(E) is empowered to condone such delay. It was further held that mere inclusion of enabling clauses authorising application of funds outside India cannot be a ground to reject registration, particularly when the assessee has taken steps to amend its Memorandum. Such issues may be examined at the assessment stage. Accordingly, the delay of 33 days was condoned and the matter restored to the CIT(E) for fresh consideration on merits and to verify whether the amendment to the Memorandum has been duly effected. (Followed: Vaishya Welfare Gaushala v. UOI (2024) 167 taxmann.com 582 (Chh.)(HC); Sitaldas K. Motwani v. DGIT (2010) 323 ITR 223 (Bom)(HC); K.P. Varghese v. ITO (1981) 131 ITR 597 (SC)). (A.Y. 2024–25) ( ITA No. 2617/Mum/2025, dt.  14.10.2025 )