(1.) This appeal filed by the Assessee is directed against the order passed by the Income Tax Appellate Tribunal Bench "B", Chennai, in I.T.A.No.324/Mds/2008, dated 25.09.2008.
(2.) This appeal has been admitted vide order dated 27.07.2009 on the following substantial questions of law:
(3.) The Assessee filed an application under Section 12AA of the Income Tax Act, 1961 (in short, "the Act") on 30.05.2007 for grant of registration of trust said to have been created on 10.02.1988. Section 12AA mandates that the application for registration ought to have been filed within one year from the date of creation of the Trust. Admittedly, the Assessee's application was filed after a delay of 18 years, 3 months and 21 days. The Commissioner of Income Tax vide order dated 06.11.2007 considered the application and granted registration under Section 12A(a) of the Act with effect from 01.04.2007 relevant to the Assessment Years 2008-2009 and onwards, i.e., prospectively.