Assessee, a charitable institution under section 12AA, was granted provisional approval under section 80G(5)(iv). Assessee thereafter applied for final approval under section 80G(5)(iii).Application is  rejected by Commissioner (E) on ground that time limit prescribed for making an application for final approval was at least six months prior to expiry of period of provisional approval or within six months of commencement of its activities, whichever is earlier and since time period for making application mentioned in section 80G(5)(iii) had already expired, assessee could not be granted final registration under section 80G(5). On appeal the Tribunal held that after grant of provisional approval, application could not be rejected on ground that institution has already commenced its activities even prior to grant of provisional registration and date of commencement of activity will be counted when an activity is undertaken after grant of provisional registration either under clause (i) or clause (iv) to first proviso to section 80G(5). Accordingly the application filed by assessee being within limitation period, order of Commissioner (E) is set aside. CIT(E) is directed to decide the application for final registration within three months of receipt copy of order.