Section 12AA(2) of the Income Tax Act, 1961 does not recognize...

Section 12AA(2) of the Income Tax Act, 1961 does not recognize any deemed grant of registration if the application is not decided within six months. The Supreme Court in Harshit Foundation Sehmalpur upheld the Allahabad High Court's decision in Muzaffar Nagar Development Authority, which held that the Parliament has not provided for such a deeming fiction. This decision is the law declared by the Supreme Court under Article 141 of the Constitution. The decisions in Society for Promotion of Education and Harshit Foundation Sehmalpur are not mutually irreconcilable, as they address different aspects of the interplay between Sections 12A and 12AA(2). The specific deeming provision in Section 12AA(2) does not conceive any deemed registration if the application is not decided within six months.