Section 11 exemption upheld where 12AA registration existed before reassessment and later effective date did not defeat relief.

Registration under section 12AA, once obtained before the reassessment order was passed, could not be ignored for denying exemption under section 11 merely because the registration carried a later effective date. The Tribunal applied the second proviso to section 12A and held that the assessee's eligibility had to be tested on the registration position existing at the time of reassessment. The Revenue's reliance on the cited precedent was distinguished on facts. The exemption claim was therefore allowed and the disallowance of the benefit was set aside.

---

---

Issues: Whether exemption under section 11 could be denied for assessment year 2017-18 on the ground that registration under section 12AA was granted later and could not operate retrospectively, and whether the second proviso to section 12A protected the assessee's claim in reassessment proceedings.

Analysis: The assessee had obtained registration under section 12AA before the reassessment order was framed. The lower authorities declined the exemption only because the registration was granted with effect from a later date and, therefore, was said not to extend retrospectively. The Tribunal held that the second proviso to section 12A governed the situation and that the benefit of registration could not be denied merely because the reassessment was completed after the registration had been granted. The Tribunal also distinguished the Revenue's reliance on the cited precedent on the facts, holding that the registration position available on the date of reassessment was material.

Conclusion: The assessee was entitled to the exemption claim and the disallowance of the benefit was set aside.

---