The insertion of Section 13(9) read with Section 11(2) is a major setback for charitable organizations since they might be denied exemptions only for delayed filing of a particular form.

There are multiple decisions of various high courts wherein the filing of forms have been considered as directory and not mandatory. So the provisions brought in might be too harsh for charitable organizations considering the nature of work they are executing.

However, giving relief to the organizations in the first year, CBDT authorized the CIT-E to admit the applications for condonation of delay.

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