Fresh Section 12AB registration applied from assessment year 2022-23, preserving Sections 11 and 12 exemption for the prior year.

Fresh registration under Section 12AB for existing charitable trusts applied from assessment year 2022-23 under the amended registration regime. The amendment introduced by the Taxation and Other Laws Amendment Act, 2020 did not apply to assessment year 2021-22. Accordingly, exemption under Sections 11 and 12 could not be denied for assessment year 2021-22 merely because fresh Section 12AB registration had not then been obtained. The trust obtained fresh registration on 24.09.2021.

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Issues: Whether exemption under Sections 11 and 12 was deniable for assessment year 2021-22 because the trust had not obtained fresh registration under Section 12AB.

Analysis: The requirement for existing charitable trusts to obtain fresh registration under the amended regime applied from assessment year 2022-23. The amendment introduced by the Taxation and Other Laws Amendment Act, 2020 did not govern assessment year 2021-22. The trust also obtained fresh registration on 24.09.2021.

Conclusion: Exemption under Sections 11 and 12 could not be denied for assessment year 2021-22 for want of fresh registration under Section 12AB; the issue was decided in favour of the assessee.

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