HC: Rejects society's Sec 12AA registration claim from original application date; Reverses ITAT ruling

Allahabad HC sets-aside ITAT order, grants registration u/s. 12AA to assessee-society with effect from April, 2004 (date of filing fresh application) and not from  the date of original application u/s. 12AA in April, 2000;  Assessee-society had originally filed the application for registration u/s. 12AA in November, 2000, which was rejected and upon filing of representation before CIT in September, 2004 against such rejection, assessee’s application was allowed, whereby registration was granted w.e.f.  April, 2004 and not from 2000; ITAT however had allowed assessee's plea to grant the registration from the year 2000, which is rejected by the High Court; HC holds that the date of filing the original application for registration has no relevance when the said application was rejected, and the subsequent application/representation moved in September, 2004 should be treated as a fresh application and accordingly the registration of the society u/s. 12AA would be operative from April, 2004; Further, HC notes that CIT, without recalling or setting aside its earlier order, had unequivocally granted registration from 2004 onwards:HC