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2024 (2) TMI 1395

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..... anjay 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 ld. CIT(Exemptions) observed that the assess .....

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..... (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 application in the prescribed form and manner to the Principal Comm .....

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..... 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 application before the period of six months from the expiry of the provisiona .....

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