Exemption Denied u/ss 11 & 12 Due to 12AA, But Proviso to 12A(2) Applies During Appeals.

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....Exemption u/s 11 and 12 denied - deemed registration u/s 12AA - the benefit of the proviso to section 12A(2) is available not only when the assessment proceedings are pending before the AO but also when an appeal against the assessment order is pending before the ld. CIT(A). It is so for the reason that the appeal proceedings are nothing but continuation of the assessment proceedings.....