Charitable registration under section 12AA operates prospectively after amended objects bring an association within the charitable regime.

Registration under section 12AA could not be related back to the association's date of inception where its original memorandum and bye-laws were aimed at members' interests and were not charitable. The earlier refusal of registration was not challenged, and the later modification of objects was introduced to bring the association within the charitable regime and secure section 11 benefits. In the absence of evidence of charitable activity under the original objects, the change operated only from the date the objects were modified. Registration was therefore warranted prospectively from 13 March 2000, not retrospectively.

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Issues: Whether registration under section 12AA of the Income-tax Act, 1961 could be directed to take effect retrospectively from the date of inception of the assessee-association, notwithstanding the later modification of its objects.

Analysis: The original memorandum and bye-laws were found to serve the interests of the members and were not treated as charitable. Registration had earlier been rejected, and no challenge was pursued against that rejection. The association thereafter modified its objects and sought registration again. The modified objects were introduced to align the association with charitable purposes and to avail the benefit of section 11. A change in objects that brings the institution within the charitable regime operates from the date of modification and cannot, in the absence of evidence of charitable activity under the earlier objects, be related back to the date of inception.

Conclusion: Registration could validly be granted only prospectively from 13 March 2000, and retrospective registration from the date of inception was not warranted.

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