Registration under Sections 11 and 12 is a condition precedent; earlier-year exemption fails where registration does not cover those years.

Exemption under sections 11 and 12 was unavailable for the relevant assessment years because the assessee did not hold valid registration under section 12A, 12AA or 12AB for those years. Registration in Form 10AC operated only from assessment year 2022-23, and the earlier years were outside its scope; the proviso extending benefit to earlier years did not apply because no assessment proceedings were pending when registration was granted. As a result, the nature of the collections as betterment fees or lake rejuvenation fees did not change their tax treatment, and the claim that they qualified as exempt receipts under section 11(1)(d) was rejected.

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Issues: Whether the assessee, in the absence of valid registration under the Income-tax Act for the relevant assessment years, could claim exemption under sections 11 and 12 and treat the collections from betterment fees and lake rejuvenation fees as exempt receipts under section 11(1)(d).

Analysis: The assessee's entitlement to exemption depended first on satisfying the statutory condition of registration under section 12A, 12AA or 12AB. The registration granted in Form 10AC was effective only from assessment year 2022-23, and the earlier assessment years under appeal were not covered by that registration. The record also showed that no assessment proceedings were pending on the date of grant of registration so as to attract the proviso enabling earlier-year benefit. In the absence of valid registration for the relevant years, the scheme of sections 11 and 12 could not be invoked, and the character of the collections as statutory or capital receipts did not alter that result.

Conclusion: The claim for exemption under sections 11 and 12 was not admissible for the assessment years in question, and the assessee's contention that the disputed collections fell within section 11(1)(d) was rejected.

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