2024 (2) TMI 1395

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....kesh Kumar Das, CIT-DR ORDER Per Sanjay Garg, Judicial Member: The present appeal has been filed by the assessee against the rejection of his application for final registration u/s 12A(1)(ac)(iii) of the Income Tax Act (hereinafter referred to as the 'Act'). 2. The ld. CIT(Exemptions) has rejected the application holding the same to be prima facie not maintainable being premature. The ....

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....relevant part of the provisions of section 12A(1)(ac) of the Act is reproduced as under: "12A(1) The provisions of section 11 and section 12 shall not apply in relation to the income of any trust or institution unless the following conditions are fulfilled, namely:- [(ac) notwithstanding any contained in clauses (a) to (ab), the person in receipt of the income has made an applica....

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....onths of the commencement of its activity, whichever is earlier, which means that the application for final registration has to be made at the earliest possible event i.e. either within six months of the commencement of the activities or at least six months prior to the expiry of the provisional registration. The aforesaid provision does not mean that there is any bar on the applicant to move an a....