https://www.taxtmi.com/caselaws?id=385287 Allahabad HC allowed revenue's appeal against tribunal's order granting retrospective exemption under Section 11. The assessee trust received registration under Section 12AA on 08.06.2015 after applying on 15.12.2014, but claimed exemption from AY 2011-12. HC held that exemption benefit is available only from the assessment year following the financial year of application, not retrospectively. The proviso to Section 12A(2) requires assessment proceedings to be pending before the Assessing Officer, not tribunal. Since AY 2011-12 proceedings were pending before tribunal when application was made, retrospective benefit was denied. HC emphasized that exemption provisions should be interpreted strictly in favor of revenue, unlike charging provisions where ambiguity benefits assessee. en-us Tue, 06 Aug 2019 00:00:00 +0530 Sat, 31 May 2025 17:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385287 Allahabad HC allowed revenue's appeal against tribunal's order granting retrospective exemption under Section 11. The assessee trust received registration under Section 12AA on 08.06.2015 after applying on 15.12.2014, but claimed exemption from AY 2011-12. HC held that exemption benefit is available only from the assessment year following the financial year of application, not retrospectively. The proviso to Section 12A(2) requires assessment proceedings to be pending before the Assessing Officer, not tribunal. Since AY 2011-12 proceedings were pending before tribunal when application was made, retrospective benefit was denied. HC emphasized that exemption provisions should be interpreted strictly in favor of revenue, unlike charging provisions where ambiguity benefits assessee. Case-Laws Income Tax Tue, 06 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385287