Soundaram Chokkanathan Educational and Charitable Trust v. ITO (2021) 430 ITR 440 / 197 DTR 440/ 279 Taxman 210 (Mad.)(HC)

S. 12A : Registration-Trust or institution-Trust deed amended and registration granted with effect from 1-4-2015-Application filed on 23-02 2016-Registration would not have retrospective effect and be applicable from assessment Year 2013-14.

Court held that the assessee was precluded from contending that the first proviso under section 12A of the Income-tax Act, 1961, should be made applicable to it and that it should be granted with the benefit from the assessment year 2013-14, because only after the deed of trust was amended, was the application considered and registration had been granted with effect from April 1, 2015 only. Therefore, the Tribunal rightly held against the assessee, stating that there was nothing on record to show that the exemption activities and operations and genuineness of its claims for the assessment year 2013-14 was examined. Since registration had been granted only after the deed of trust was amended, the assessee could not claim the benefit of registration from the assessment year 2013-14. (AY. 2013-14)