Proviso to S.12A(2) is declaratory and will have and has retrospective effect [ S. 11]

Sir, my query is was the following judgement of Rajasthan High Court challenged by CIT in Supreme Court ? thanking you Siddharth CIT v. Shree Shyam Mandir Committee. (2018) 400 ITR 466 (Raj) (HC) S. 12A : Registration –Trust or institution- Appeal before CIT(A) is continuation of original assessment proceedings —.Proviso to S.12A(2) is declaratory and will have and has retrospective effect [ S. 11]

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