Assessee was already registered/approved under section 80G(5) as a charitable institution since 1999. However, post amendment brought into relevant provisions of section 80G vide Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 with effect from 1-4-2021, assessee applied for provisional approval under clause (iv) to first proviso to section 80G(5).  Assessee was granted same on 10-3-2023 for a period of 10-3-2023 to assessment year 2025-26. Thereafter, assessee applied for final approval under clause (iii) to first proviso to section 80G(5). Commissioner (E), rejected application of assessee observing that assessee had already commenced its activities since long even prior to grant of provisional registration, and further, since time period for making application mentioned in clause (iii) to first proviso to section 80G(5) had already expired on 30-9-2022 vide CBDT Circular No. 18/2022, therefore, assessee could not be granted final registration under section 80G(5).On appeal the Tribunal held that  after grant of provisional approval, application for final registration could not be rejected on ground that institution had already commenced its activities even prior to grant of provisional registration and under such circumstances, date of commencement of activity would be counted when an activity was undertaken after grant of provisional registration either under clause (i) or clause (iv) to first proviso to section 80G(5). Since  the assessee had applied for final registration after grant of provisional registration, application filed by assessee was within limitation period and, therefore, Commissioner (E) is   directed to grant provisional approval to assessee under clause (iii) to first proviso to section 80G(5) and then decide application for final registration. ( AY. 2025-26)