Substance over form in exemption registration: wrong code application required reconsideration under the new circular for fresh assessment.

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....A claim for exemption registration filed under the wrong section code required fresh scrutiny in light of Circular No. 7/2024 and the substance-over-form principle. The HC noted that the Tribunal had not examined the circular issue, and the appellant's assertion of system error was not established on the existing record. However, because the appellant had earlier held Section 12A registration, later obtained registration under Section 10(23), and surrendered it, the competent authority had to consider whether the mistaken code and fresh application brought the case within the circular. The impugned orders were set aside and the matter remitted for reconsideration without any view on merits.....