The assessee’s application for registration under section 12AA was initially rejected but was subsequently allowed pursuant to the Tribunal’s directions with effect from the relevant assessment year. After obtaining registration, the assessee filed the audit report in Form No. 10B. The Tribunal held that when the return was originally filed the assessee was not a registered trust and therefore could not have complied with the requirement of filing Form No. 10B. Filing the audit report after grant of registration constituted substantial compliance and exemption under sections 11 and 12 could not be denied on that ground. The Revenue denied exemption on the ground that the return was not filed within the time prescribed under section 139(4A). The Tribunal held that the requirement inserted by section 12A(1)(ba) applies only from assessment year 2018-19 onwards. For the year under consideration, the assessee having filed the return within the period prescribed under section 139 was entitled to exemption. The denial of exemption was therefore held to be unsustainable.  (AY. 2017-18).