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TMI Blog2017 (9) TMI 527X X X X Extracts X X X X X X X X Extracts X X X X ..... tial compliance was made later on, it cannot be said that the date of making such compliance is the date of the Application. Every single compliance relating to the procedure was made and when the Revenue did not dispute that the registration under Section 12A is valid, that prior to the instant application the certificate under Section 80G was granted, then all the more, we do not think that the Tribunal's order raises any substantial question of law. - Income Tax Appeal No. 1735 of 2014 - - - Dated:- 4-9-2017 - S. C. Dharmadhikari And Prakash D. Naik, JJ. Mr. Sham V. Walve for the Appellant Ms. Lucy Massey for the Respondent ORDER P. C. 1. This Appeal challenges the order of the Tribunal dated 27th January, 2014 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d not make any other application in Form No.10G save and except the application on which the order the Commissioner was passed. The Commissioner noted that the application was not accompanied with the copies of the financial statements for the years ended 31st March, 2010 and 31st March, 2011, but had attached a financial statement for the years 2006-2007, 2007-2008 and 2008-2009. The Commissioner also observed that the application was not accompanied by any notes on activities carried out during the three preceding years. The Commissioner, relying on Rule 11AA, observed that the requirement therein is mandatory and the assessee has not complied with the same. The Application was also not accompanied by a copy of the Memorandum of Associati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of 23-06-2004 to 31-03-2007. The assessee filed the application on 02-11-2011. There was some procedural compliance required to be made and the same has been complied with by the assessee on 20-04-2012. The Ld. CIT, therefore, treated the valid date of filing of the application is 20-04-2012. In our opinion, whatever the CIT has pointed out these are only the procedure requirements and the assessee has made the compliance during the pendency of his application hence, we hold that the assessee has filed the valid application on 02-11-2011 and for considering the approval u/s. 80G the same date is to be taken into consideration. 10. We do not think that any larger question or wider controversy should be decided. Every single compliance ..... X X X X Extracts X X X X X X X X Extracts X X X X
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