ORDER BY THE COURT : In this petition, the petitioner-society has challenged the order dt. 3rd November, 1993 (Annexure P-6 to the petition) passed by the CIT, Bhopal, by which the learned CIT has declined to grant benefit of the provisions of s. 11 of the IT Act for the period earlier to 1st April, 1994. The petitioner applied for registration under s. 12A of the IT Act, 1961, by application dt. 13th July, 1993, which was granted to the petitioner by the impugned order dt. 3rd November, 1993 only w.e.f. 1st April, 1993 and not from the date of its establishment. As condonation of delay in making the application was refused, the petitioner-society filed an application for review, which remained undecided with the result the petitioner has filed this petition. 2. Sec. 12A of the IT Act, 1961, reads as under : "12A. The provisions of s. 11 and s. 12 shall not apply in relation to the income of any trust or institution unless the following conditions are fulfilled, namely : (a) the person in receipt of the income has made an application for registration of the trust or institution in the prescribed form and in the prescribed manner to the Chief CIT or CIT before the 1st day of July, 1973, or before the expiry of a period of one year from the date of the creation of the trust or the establishment of the institution, whichever is later : Provided that where an application for registration of the trust or institution is made after the expiry of the period aforesaid, the provisions of ss. 11 and 12 shall apply in relation to the income of such trust or institution, - (i) from the date of the creation or the trust of the establishment of the institution if the Chief CIT or CIT is, for reasons to be recorded in writing, satisfied that the person in receipt of the income was prevented from making the application before the expiry of the period aforesaid for sufficient reasons; (ii) from the 1st day of the financial year in which the application is made, if the Chief CIT or CIT is not so satisfied; (b) where the total income of the trust or institution as computed under this Act without giving effect to the provisions of s. 11 and s. 12 exceeds fifty thousand rupees in any previous year, the accounts of the trust or institution for that year have been audited by an accountant as defined in the Explanation below sub-s. (2) of s. 288 and the person in receipt of the income furnishes along with the return of income for the relevant assessment year the report of such audit in the prescribed form duly signed and verified by such accountant and setting forth such particulars as may be prescribed." 3. The learned CIT has rejected the request of the petitioner for benefit of the provisions from the date of the registration of the society on the ground that the application was filed in the prescribed proforma after one year and six months and the reasons furnished were not satisfactory. It is this part of the order that the petitioners have challenged. 4. Learned counsel for the petitioner submitted that the society was registered under the M. P. Societies Registration Act, 1973, on 31st October, 1991 and therefore, the petitioner society was required to make an application for registration in the prescribed proforma by 31st October, 1992. The application, even as per the impugned order, is said to have been made by the society on 13th August, 1993 and, therefore, it cannot be said by any stretch of imagination that the application had been made after one year and six months of the prescribed period. The application, even as per the impugned order, is said to have been made by the society on 13th August, 1993 and, therefore, it cannot be said by any stretch of imagination that the application had been made after one year and six months of the prescribed period. It was made after about nine months of the prescribed period and therefore, the rejection of the prayer for grant of benefit from the date of registration of the society on the ground that the application was made out of time by one year and six months, is vitiated on account of the said factual error. 5. Sec. 12A authorises Chief CIT or CIT, for reasons to be recorded in writing, to make the provisions of ss. 11 and 12 applicable from the date of creation of the trust or the establishment of the institution on satisfaction that the person making the application was prevented by sufficient cause from making the application before expiry of the period. Expression "before expiry of the period" in proviso (i) of cl. (a) of s. 12A requires sufficiency of reasons which prevented the persons from making the application within one year as required and not the reasons for the period beyond the prescribed period of one year. What the authority has to see is whether or not there were sufficient reasons which prevented the person from making the application within the prescribed period and not the total period after which the application was made. The learned CIT was, therefore, required to examine whether sufficient reasons existed for not making the application in the prescribed proforma within the prescribed period of one year and not with reference to the total period that elapsed before making of the application. It is, thus, clear that the learned CIT has not approached the matter from its correct perspective. 6. The learned CIT has recorded that the reasons furnished were not satisfactory. "Not satisfactory" is a conclusion and cannot be a reason by itself and it was necessary for the learned CIT to have given reasons why explanation for not making the application in time was not satisfactory. It is clear from the impugned order that insofar as the entitlement to registration under s. 12A is concerned, the same has been granted though with prospective effect from 1st April, 1993. It is clear from the impugned order that insofar as the entitlement to registration under s. 12A is concerned, the same has been granted though with prospective effect from 1st April, 1993. The eligibility of the petitioner having thus been concluded, it was necessary that cogent reasons were assigned to indicate why the reasons furnished by the petitioner were not satisfactory. 7. The grievance of the petitioner is also that the petitioner was not granted any opportunity of hearing. Learned counsel for the Department has pointed out that after the application was received, the petitioner was sent the communication dt. 18th August, 1993 (Annexure P-4) to furnish information including the reasons for delay in making the application beyond the period of one year, to which the petitioner had reported compliance under its letter dt. 29th September, 1993 (Annexure P-5). The learned counsel for the Department, therefore, contends that no further opportunity was necessary especially when the provision does not contemplate the granting of hearing to the party concerned. It is not disputed that refusal to condone the delay in making the application entails consequence of the denial of the benefit of the provisions of ss. 11 and 12 from a date anterior to the date from which benefit is granted in the financial year in which the application is made. Since the consequence of refusal has the effect of denial of benefit, principles of natural justice require an opportunity of hearing before an order in this behalf is passed on the ground that the reasons furnished by the applicant were not satisfactory. Thus, examined from any angle, the impugned order, insofar as it denies the benefit for the period prior to 1st April, 1993, cannot be sustained and the matter deserves to be remitted back to the learned CIT for decision in accordance with law. 8. Accordingly, this petition is partly allowed. The matter is remitted back to the learned CIT to consider the application for grant of benefit under s. 11 with effect from the date of registration of the petitioner-society and for decision in accordance with law. There shall, however, be no order as to costs.