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Final registration granted on the assessee's original charitable-trust application was treated as relating back to the relevant assessment period, so exemption could not be denied merely because the final order was passed after assessment while provisional registration was already in force. The tribunal noted that the later final registration covered the year in question and upheld exemption for the assessment year. It further held that expenditure on school infrastructure, including repair and construction of classrooms and basic amenities, was allowable as application of income even if capital in nature, and the addition was deleted because the expenditure was genuine and actually incurred.
Final registration granted on the assessee's original charitable-trust application was treated as relating back to the relevant assessment period, so exemption could not be denied merely because the final order was passed after assessment while provisional registration was already in force. The tribunal noted that the later final registration covered the year in question and upheld exemption for the assessment year. It further held that expenditure on school infrastructure, including repair and construction of classrooms and basic amenities, was allowable as application of income even if capital in nature, and the addition was deleted because the expenditure was genuine and actually incurred.
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