CBDT, vide Circular No. 8 of 2022 dated 31-3-2022, extended time limit with respect to both existing trusts and new trusts for registrations under sections 10(23C), 12A and 80G(5). However, CBDT, while extending time limit further vide impugned Clause 5 (ii) of Circular No. 6 of 2023, dated 24-5-2023, did not grant extension to new trusts for filing forms for application of registration under clause (iii) of first proviso to section 80G(5)  of the Act. The assessee filed writ petition challenging the circular as arbitrary. Allowing the petition the Court held that, revenue could not provide any rationale for such a classification. Even though new trusts as well as existing trusts had no right to demand for extension of time as a matter of right, when revenue had thought it fit to extend time, considering hardship, there was no material placed before Court, nor any reasoning as contained in impugned order that new trusts did not face hardship in respect of filing of application under section 80G(5) alone.  Further, leaving out clause in respect of section 80G(5) alone, that too only in respect of new trusts did not in any manner relate to object sought to be achieved by impugned circular nor did it provide any basis for discrimination/classification. Differential treatment was not based on any substantial distinction that was real and pertinent to object of circular. Therefore,  clause 5(ii) of circular No. 6/2023, dated 24-5-2023 was arbitrary and violative of article 14 of Constitution of India and accordingly, would be ultra vires Constitution. Circulars and Notifications: Circular No.8 of 2022, dated 21-3-2022 and Circular No.6 of 2023, dated 24-5-2023