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Whether the Income Tax Appellate Tribunal was justified in holding that the assessee is eligible for exemption u/s 11 of the Act even when the assessee was not registered u/s 12AA of the Act at the time of passing of the assessment order?

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Section 12A of the Income Tax Act, 1961 — Registration of trust — Application for registration having been given on 15th Dec, 2014 i.e. in financial year 2014-15 on registration of the trust. benefit under section 11 and 12 would be available for A.Y. 2015-16 in view of proviso to section 12A(2). registration could not be granted from A.Y. 2011-12 even if the matter was pending before Tribunal when application for registration was submitted on 15th December 2014. words used are pendency of the assessment proceedings before the AO and not pendency of assessment proceedings — Commissioner of income tax vs. Shiv Lumar Sumitra Devi Smarak Shikshan Sansthan [2019] 310 CTR (Allahabad) 714

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