Assessee-company with charitable objects was incorporated on 17-2-2020. It received provisional approval under section 80G(5) on 1-12-2022. It commenced its activities on 3-1-2023. It filed application in Form No. 10AB for permanent registration under section 80G(5) on 30-9-2023. Commissioner (E) rejected application on ground that it was not filed within six months of commencement of activities and was beyond time permitted in section 80G(5). Words ‘within six months of commencement of its activities’ used in clause (iii) of first proviso to section 80G(5) had to be interpreted that they applied for those trusts/institutions which had not started charitable activities at time of obtaining provisional registration and not for those trusts/institutions which had already started charitable activities before obtaining provisional registration.  Asessee had applied for registration within time allowed under clause (iii) of first proviso to section 80G(5).Order of Commissioner (E) is  be set aside for de novo adjudication.