Mandi samiti registration under income-tax law was upheld despite delayed application after the exemption regime changed.

A statutory mandi samiti formed under the relevant State enactment was treated as eligible for registration as a trust for income-tax exemption purposes, because its functions were directed to regulating agricultural produce and providing related facilities. The belated application for registration under section 12A/12AA was not treated as fatal, since registration was not required before 1.4.2003 and the exemption regime had changed thereafter. On that basis, condonation of delay and retrospective registration were upheld, and the revenue's challenge failed in light of the earlier binding decision on similar mandi samities.

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Issues: Whether the Tribunal was justified in condoning the delay in filing the application for registration and in directing grant of registration under section 12A/12AA of the Income-tax Act, 1961 with effect from 1.4.2003.

Analysis: The challenge was held to be covered by the Court's earlier decision in similar matters concerning mandi samities constituted under the relevant State enactment. It was accepted that such statutory bodies, functioning to regulate agricultural produce and provide facilities to , were entitled to registration as trusts for claiming exemption under the Income-tax Act, 1961. The delay in moving the application was treated as not fatal in view of the legal position that registration was not required prior to 1.4.2003 and the subsequent change in the exemption regime.

Conclusion: The condonation of delay and grant of registration with retrospective effect were upheld in favour of the assessee.

Final Conclusion: The appeal failed and the questions of law were answered against the revenue on the basis of the earlier binding decision.

Ratio Decidendi: A statutory mandi samiti entitled to exemption under the pre-amendment regime cannot be denied registration under section 12A/12AA merely because its application was filed belatedly after the legal requirement for such registration arose.

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