The AO held that the Assessee society was neither registered under section 12A nor approved under section 10(23C)(vi). Therefore excess of income over expenditure, which was transferred to its reserve and surplus account was added to the returned income. In Appeal CIT( A) confirmed the order of the AO. On appeal to the Tribunal , allowing the appeal of the assesse the Tribunal held that ; first proviso to section 12A(2) inserted by Finance (No. 2) Act, 2014, with effect from 1-10-2014, being a beneficial provision intended to mitigate hardships in case of genuine charitable institutions, has to be applied retrospectively. Therefore, the order of the CIT(A) is set aside and, consequently, the addition sustained by here is deleted. ( AY. 2011-12 )