Assessee was granted provisional approval under section 80G(5)(vi) till assessment year 2024-25. Assessee filed an application under section 80G(5)(iii) on 27-1-2023.The said application was rejected by Commissioner (E) on ground that since activities of assessee were already commenced before date of provisional approval on 19-11-2019, assessee was required to file application within six months from date of provisional approval.On appeal following the ratio of the judgement of the   Tribunal, vide order dated 5-1-2024 in Kailash Math Trust v. CIT (E) [ITA no. 1177/PUN/2023], held that words ‘within six months of commencement of its activities’ are to be interpreted to be applicable in those cases where trust or institutions have not started activities at time of grant of provisional approval. On facts  since provisional approval granted to assessee would be valid till assessment year 2024-25, application filed by assessee would be within time limit permissible under section 80G(5)(iii) and since Commissioner (E) rejected application filed by assessee only on this technical ground and had not analysed application on merits as per requirements of section 80G(5), matter is   remanded back for de novo consideration.