The assessee contended that it had filed application seeking 12A registration on 25/05/1999 in support of which the assessee filed letters and RTI replies, whereas, the revenue contends that the assessee for the first time filed the 12A application back dated, on 21/02/2002. The Revenue contended before the Hon’ble High Court as well as before this Tribunal that office of the PCIT Belgam came into existence in June 2001, and therefore it is not possible that the assessee could have filed the alleged application that bares the acknowledgement of ITO Belgam, during the period when the office was not in existence. Matter is remanded back to the CIT to verify the inward register first maintained by the Belgaum office and to verify the seal in order to establish whether the alleged application dated 25/05/1999 was existing with the revenue records prior to 2002.