Subsequent 12A registration does not validate an unsubstantiated trust expenditure claim or undo reassessment

An unregistered charitable trust's expenditure claim was disallowed because it failed to furnish supporting details or evidence before the Assessing Officer or the Tribunal. Subsequent registration under section 12A did not cure the defect, as section 12A(2) applies only where assessment proceedings are pending before the Assessing Officer on the date of registration. Proceedings pending in appeal could not be treated as proceedings pending before the Assessing Officer in light of the statutory definition of "Assessing Officer" in section 2(7A). The claim for deduction was therefore rejected, the addition sustained, and the challenge to reassessment failed.

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Issues: Whether the expenditure claimed by an unregistered charitable trust was allowable in assessment and whether the reassessment could be invalidated on the basis of subsequent registration under section 12A.

Analysis: The assessee did not place supporting details or evidence before the Assessing Officer or before the Tribunal to substantiate the claim for deduction of expenditure. The registration under section 12A was granted only after completion of the assessment, and section 12A(2) did not assist the assessee because the proviso applies where assessment proceedings are pending before the Assessing Officer on the date of registration. Proceedings pending before the appellate authority could not be treated as proceedings pending before the Assessing Officer in view of the definition in section 2(7A).

Conclusion: The claim for allowance of expenditure was rejected and the addition sustained, and the assessee's challenge to the reassessment failed.

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