(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 upto the asst. yr. 1998 -99, it was exempted under s. 10(22) of the IT Act, 1961, (hereinafter referred to as the 'Act' for short), therefore it did not seek separate registration under s. 12A of the Act, so as to claim exemption under s. 11. Sec. 10(22) being omitted by the Finance Act, 1998, the petitioner applied for registration under s. 12A of the Act, with application), the application was required to be made within one year from the date of creation of establishment of the trust or institution, therefore, condonation of delay was sought in terms of s. 12A(a) proviso (i).
(3.) SEC . 12AA(2) reads as follows :