Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh
Charitable Trust (supra) dealt with only the issue/terminology of "whichever is earlier" which is applicable to new trust which have created recently, and it does not deal with condonation of delay CIT (Exemption) Bhopal in case of old trust who made the application before learned CIT(Exemption) very late, that is, the issue mention in cl. (iii) of 3rd proviso