In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
12A is given by Ld. Commissioner of Income Tax on the basis of which the AO gives exemption to the assessee. It is also to be appreciated that section 11 exemption is a yearly process whereby the AO has to grant exemption under section 11 while satisfying himself in the assessment proceedings for each assessment year separately. Your honour will