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TMI Blog2024 (8) TMI 1464X X X X Extracts X X X X X X X X Extracts X X X X ..... 022 also clarified that the extended period upto 30/09/2023 shall apply even in cases, (i) where the application was rejected by the CIT(E) on or before issuance of this circular dt 24/05/2023 (ii) where due date for making/filing application has expired, on or before 30/09/2023. In addition to above, in reply to a specific query, the appellant spelt out the reasons beyond delayed filing of application, which in our considered view also formed sufficient reasonable ground to condone the delay. We find in similar facts circumstance, the co-ordinate benches allowed benefit of extended time period in Rotary Club of Akurdi Charitable Trust [ 2024 (10) TMI 1246 - ITAT PUNE] , Shashvat Paediatric Care Foundation [ 2024 (3) TMI 1365 - ITAT PUNE] , ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t. 09/07/2021 was issued. In compliance of terms of condition of provisional registration and applicable provisions of the Act, the assessees vide its application From No. 10AB CIT EXEMPTION, PUNE/2023-24/12AA/13479 dt. 30/09/2023 applied for regular/final 80G approval/registration, this application however by the impugned order is rejected by the Ld. CIT(E) in limine on the ground that the application is barred by limitation. 3. In view of the Ld. CIT(E), since the appellant had already commenced its activities on dt. 26/02/2010 i.e. much before the issue of provisional registration hence was under obligation to file an application seeking regular 80G registration within a period of six months therefrom provisional registration granted to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erefore was under obligation to file form 10AB for regular/final registration before the expiry of six months in terms of clause (iii) of first proviso to s/s (5) of section 80G of the Act. The appellant s application dt. 30/09/2023 for grant of regular registration was however admittedly filed after the expiry of former stipulate period. As a result, the application was rejected by the Revenue in limine on threefold grounds viz; (i) the application is barred by limitation, (ii) the appellant was not entitled to the extended time period in terms of circular 08/2023 dt. 24/05/2023 and (iii) in absence of explicit provision/power to condone the delay in filing application for regular/final registration. There is no dispute over (i) and (iii) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on to donation made after 31/03/1992. That is to say the assessee who is granted provisional registration by an order u/c (vi) of 80G(5) would then be entitled to extended time by virtue of 5(i) r.w. para 1(c) of circular (supra) and not otherwise. 7. In the present case before us, reading from para 4 of impugned order it as an undisputed fact that the appellant assessee was granted a provisional registration u/c (iv) of s/s (5) of section 80G of the Act by an order u/c (vi) of s/s (5) of section 80G of the Act by the Ld. CIT(E). Therefore, there remains no reason to draw out appellant s case from claiming benefit of extended period for filing application for regular registration. Further the circular (supra) also clarified that the extende ..... X X X X Extracts X X X X X X X X Extracts X X X X
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