Section 11 exemption requires valid Section 12AA approval for the relevant year; prospective provisional approval does not support earlier claims.

Exemption under Section 11 of the Income-tax Act, 1961 depends on valid registration or approval under Section 12AA being effective for the relevant assessment year. The material states that no such approval existed for assessment year 2022-23, while the provisional approval relied upon was granted subsequently and operated prospectively from assessment year 2025-26. As no material established that the provisional approval applied retrospectively to assessment year 2022-23, the statutory condition for claiming Section 11 exemption was not satisfied, and the exemption claim was denied.

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Issues: Whether exemption under Section 11 of the Income-tax Act, 1961 could be allowed for the assessment year 2022-23 when the assessee did not possess valid registration or approval under Section 12AA of the Income-tax Act, 1961 for that year.

Analysis: The claim for exemption under Section 11 was denied on the ground that no valid approval under Section 12AA existed for the relevant assessment year. The assessee accepted that no such approval was available for the year under consideration and relied only on a provisional approval granted subsequently. That provisional approval was shown to operate prospectively from assessment year 2025-26, and there was no material establishing its applicability to assessment year 2022-23. In the absence of registration or approval effective for the relevant year, the statutory condition for claiming exemption under Section 11 was not satisfied.

Conclusion: Exemption under Section 11 of the Income-tax Act, 1961 was rightly denied for assessment year 2022-23 for want of valid registration or approval under Section 12AA of the Income-tax Act, 1961; the issue was decided against the assessee.

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