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The case involves the rejection of an application for registration u/s 80G by the CIT(E) due to a time limit issue. The ITAT held that provisional registration is meant for newly formed trusts/institutions not yet active, distinguishing them from those already engaged in charitable activities. Trusts in the latter category, though not mandated to apply for registration u/s 80G, can do so under the new procedure. Those with provisional registration must apply for regular registration u/s 80G. The ITAT interpreted the time limit provision to apply to trusts not active at the time of provisional registration. The matter was remanded to the CIT(E) for reconsideration in line with the decision, ensuring a fair hearing. The appeal was allowed for statistical purposes.