The Tribunal held that the assessee’s application for condonation of delay was to be allowed considering that the assessee was prevented from filing the appeal in time owing to the nationwide covid-19 pandemic situation which was beyond the control of human beings. Moreover, the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 had granted extension of the limitation in the filing of appeals. The amended objects were within the scope of charitable purpose and were all approved since 2013 by the Department. There was no provision in the Act either to obtain any prior permission for making an amendment to the objects of the society or requiring the assessee to intimate the Department about the amendment. Registration under section 12AA, once granted, remained valid until it was cancelled by the Commissioner, by due process of law laid down under section 12AA(3) or (4), that too on an application made by the assessee for intimation of the amendment in the objects, which was subsequently withdrawn. The order passed under section 12A(1)(ab) was, hence, bad in law as well as on the facts merely on the ground of holding that the assessee was carrying out activities in the nature of business. CBDT Circular No. 21 of 2016 dated May 27, 2016 ^[1 also supported this stand. Moreover, each activity of the assessee satisfied the definition of section 2(15) and a comparison of receipts with the limb of section 2(15) shows that the general public utility percentage was also less than 20 per cent. So even on the merits the view of the Commissioner (E) was incorrect. As his order cancelling the registration under section 12A(1)(ab) was bad in law, the assessee’s registration was required to be continued.(AY. 2020-21)