Section 11, 12A & 12A(2) of Income-tax Act, 1961— Charitable trust—AO and the CIT(A) was not justified in taking a stand that registration under s. 12A was not applicable to the assessee for the assessment years under consideration and that the ratio laid down by Hon'ble apex Court in the case of U.P. Forest Corporation vs. Dy. CIT that registration of a trust under s. 12A is a condition precedent to claim of exemption under sections 11 and 12 has been is not applicable to the peculiar facts of the case in view of the amendment to the s. 12A(2) by way of inserting proviso through Finance Act, 2014 with retrospective effect and therefore, in view of the statutory provisions and the legal propositions we do not approve finding of the learned CIT(A)— Badhte Kadam vs. Dy. CIT [2020] 203 TTJ 597 (RAIPUR)