Assessee is  an educational institution, filed its return of income claiming exemption on entirety of its gross receipt under section 11. Claim was denied under section 143(1)(a).  Assessee moved an application under section 154 stating that it’s income for relevant year was only Rs.11.19 lakhs, balance being corpus donation is  eligible for exemption under section 11(1)(d).  Assessing Officer rejected application filed by assessee on ground that assessee is  not registered under section 12AA.  Meanwhile, assessee applied for registration under section 12AA which was granted on 20-8-2016 with effect from assessment year 2015-16. On appeal the CIT(A) affirmed the order of the AO. The Tribunal   held that the assessee being admittedly not registered under section 12AA for relevant year, it’s claim under section 11 could not be admitted, and was to be rejected at threshold, i.e., be it under section 11(1)(a), (b) or (d)  Since assessee’s final accounts reflected a loss on operations, which were mistakenly returned as income, matter was to be remanded to Assessing Officer for taking on record audited final accounts on basis of which assessee had returned income and then passing an order under section 154. Assessee moved an application under section 154 stating that it’s income for relevant year was only Rs.11.19 lakhs, balance being corpus donation was eligible for exemption under section 10(23C)(iiiad). Assessing Officer denied same for reason that assessee’s admitted gross receipt was in excess of Rs. 100 lakhs. Since provision under section 10(23C)(iiia) did not speak of gross receipt but annual receipt which would not include voluntary contribution toward corpus, assessee was entitled for exemption of its income, including capital receipt, under section 10(23C)(iiiad). (AY. 2013-14)