Subsequent registration under section 12AA required fresh consideration of trust exemption and remand of the assessments.

Denial of exemption under section 11 on the ground that the trust lacked registration under section 12AA could not be sustained once registration was subsequently granted. The later grant of registration materially affected the exemption claim, so the assessments were set aside and remanded for fresh disposal after taking the registration into account and giving the assessee a reasonable opportunity of hearing.

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Issues: Whether the denial of exemption to the trust for want of registration under section 12AA of the Income-tax Act, 1961 required setting aside of the assessments and remand for fresh consideration after subsequent grant of registration.

Analysis: The trust had been denied exemption under section 11 on the ground that it was not registered under section 12AA when the assessments were completed. It was found that registration had subsequently been granted, and that this intervening fact had a bearing on the claim for exemption. In view of this subsequent development, the assessments were not sustained as they stood and were directed to be reconsidered afresh after taking the registration into account, with reasonable opportunity of hearing to the assessee.

Conclusion: The assessments were set aside and the matter was remanded to the Assessing Officer for fresh disposal in accordance with law after considering the grant of registration.

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