Allowing the appeal of the assessee the Tribunal held that  there is no cavil or doubt that the assessee trust has filed the return of income. Tribunal held that section 12A(1)(b) of the Act has been amended w.e.f. 01/04/2023, by Finance Act, 2023, to encompass that return of income filed under section 139(1) or 139(4) of the Act will satisfy compliance of section 139(4A) of the Act. The amendment is a beneficial one and only clarifies the intention of the legislature. Further, There is no further reason to deep dive into the non–furnishing of audit report along with the return of income since the registration was granted belatedly with retrospective effect at the behest of the directions from this forum. It is excruciating to note that a demand has been created on flimsy grounds as against the assessee which is in existence since 1965. For the sake of clarity it is clarified that the assessee trust is successful in assailing the order on twin grounds of submission of return of income as well as submissions of the audit report in tandem with the provisions for the impugned assessment year. It is surprising that the learned CIT(A) had traversed in an altogether different route to sustain the addition which is also perverse and has been noted cryptically by this forum. Upon conspectus of the entire gamut of the facts and circumstances of the disputes in question the  entire addition of ₹ 11,26,85,825, merits full relief and hence the returned income be accepted.  The Tribunal also held that the Circular of CBDT is binding on Revenue . ( ITA No. 488/Nag/ 2024 dt . 21 -1 -2025  (AY. 2017 -18)