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    <title>2026 (7) TMI 1644 - ITAT KOLKATA</title>
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    <description>The first proviso to section 12A(2) is described as a beneficial and curative measure that extends subsequently granted section 12AB registration to earlier years where assessment-related appeals remain pending. As appellate proceedings continue assessment proceedings, a Tribunal appeal is treated as an assessment proceeding pending before the Assessing Officer for this purpose. Where the trust&#039;s objects and activities are unchanged, no registration was previously refused or cancelled, and more than 85% of receipts were applied each year, exemption under sections 11 to 13 is available and related additions are to be deleted.</description>
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