2011 (12) TMI 83

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....or registration was filed after a delay of 21 years, 9 months and 7 days. According to the Commissioner of Income-tax, the delay was not properly explained by the assessee. Therefore, he held that registration cannot be granted to the assessee since its inception and registration can be granted only with effect from the assessment year 2006-07. Accordingly, he granted registration to the assessee under section 12AA with effect from the assessment year 2006-07 on a prospective basis. 3. When the question of not granting registration since inception was taken in appeal before the Income-tax Appellate Tribunal, D-Bench, Chennai in ITA No.1841(Mds)/2006, the Tribunal vide order dated 14-3-2008 held that the Commissioner of Income-tax has not....

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....see is carrying on charitable activities in rural areas and therefore it was under a bona fide belief that its income will be exempt from levy of income-tax. It is the case of the assessee that it was not aware of an independent procedure necessary for registration under the Income-tax Act, 1961. 7. The learned counsel appearing for the assessee explained that even if the delay is an inordinate one, the reason is also equally convincing that it was only by an oversight that the assessee could not apply for the registration in time. He explained that the society has been legally established and carrying on the activities observing all the laws of the land and therefore was under a bona fide impression that there was no need of a separate ....