Where the assessee initially filed Form No. 10AB under an incorrect clause and thereafter filed a fresh application under the correct clause during registration proceedings, such filing was a curative step and continuation of the original proceedings and rejection of registration on the ground that the corrected application was time-barred was not justified.

40. (2026) 187 taxmann.com 993 (Mum Trib)

Akashdeep Education Trust v. ITO

A.Y.: 2026-27 Date of Order : 24.06.2026

Sections: 12A(1)(ac), 12AB

Where the assessee initially filed Form No. 10AB under an incorrect clause and thereafter filed a fresh application under the correct clause during registration proceedings, such filing was a curative step and continuation of the original proceedings and rejection of registration on the ground that the corrected application was time-barred was not justified.

FACTS

The assessee was constituted under a trust deed dated 28.10.1991 and registered with the Charity Commissioner, on 07.03.1992, and had been running educational institutions for over three decades. An earlier application under section 12AA had been rejected by the CIT(E), but on appeal in 2018, the Tribunal had directed grant of registration after examining the trust's charitable objects and genuineness of activities. Under the regime introduced by the Finance Act, 2020, the assessee was granted provisional registration under section 12AB in Form No. 10AC on 07.04.2023, valid up to 31.03.2025. Before expiry of the provisional re