(1.) COUNTER and rejoinder affidavits have been exchanged. We have heard both sides.
(2.) THE petitioner is a Society running a school. The petitioner claims that because up to the assessment year 1998 -99, it was exempted under Section 10(22) of the Income Tax Act, 1961, (hereinafter referred to as the Act for short), therefore it did not seek separate registration under Section 12A of the Act, so as to claim exemption under Section 11.
(3.) SECTION 12AA(2) reads as follows: 12AA(2) Every order granting or refusing registration under Clause (b) of Sub -section (1) shall be passed before the expiry of six months from the end of the month in which the application was received under Clause (a) [or Clause (aa) of Sub -section (1)] of Section 12A.]