The first proviso to section 12A(2) extends the benefit of...

The first proviso to section 12A(2) extends the benefit of section 12AB registration to earlier assessment years where the trust's objects and activities remain unchanged and assessment proceedings are pending. Appeals against assessments are treated as a continuation of assessment proceedings and therefore as pending proceedings for this purpose. Where the trust satisfies the applicable income-application requirement, exemption under sections 11 to 13 may be available for those prior years. The stated application extends the registration benefit to the assessment year under appeal and substantially similar subsequent years, requiring deletion of related additions.