JUDGMENT 1. Heard Sri Ghan Shyam Chaudhary, Advocate, for respondent and Sri Mudit Agarwal, Advocate, for respondent. 2. This appeal under Section 260A of Income Tax Act, 1961 (hereinafter referred to as "Act, 1961") has arisen from judgment and order dated 27.05.2014 passed by Income Tax Appellate Tribunal, Lucknow Bench ''B', Lucknow (hereinafter referred to as "Tribunal") in Income Tax Appeal No. 167/LKW of 2012. It was admitted on following substantial questions of law: "I. Whether on the facts and in the circumstances of the case, the Hon'ble Tribunal was right in holding that it could be deemed that the registration had been granted to the assessee authority if the application was neither accepted nor rejected by the CIT-I, Lucknow within a period of six months from the date of the order of the Tribunal dated 28-01-2010. II. Whether on the facts and circumstances of the case, the Hon'ble Tribunal was right in placing reliance on the judgment of jurisdictional High Court in the case of Promotion of Education Adventure Sport & Conservation of Environment vs. CIT (2008) 216 CTR 167 when it was not found to be legally correct subsequently by the jurisdictional High Court in the case of Muzaffarnagar Development Authority in ITA No. 348 of 2008 dated 05-08-2013 and the question has been referred to larger bench of Hon'ble High Court. III. Whether on the facts and circumstances of the case, the Hon'ble ITAT has failed to appreciate that the provisions of Section 12AA(2) of the Act are directory and not mandatory in view of judgements of Hon'ble Madras High Court in the case of CIT-I vs. Sheela Christian Charitable Trust (2013) 214 Taxman 551, Commissioner of Income Tax vs. Karimangalam Onriya Pengal Semipu Amaipu Ltd (2013) 214 Taxman 666 and DIT (Exemption) Chennai vs. Anjman-e-Khyrkhah-e-zam (2011) 200 Taxman 27 (Mad)." 3. The issue regarding "deemed registration" has now been finally answered by Full Bench of this Court in Income Tax Appeal No. 348 of 2008 (Commissioner of Income Tax Vs. Muzaffar Nagar Development Authority) vide opinion dated 05.02.2015. The issue regarding "deemed registration" has now been finally answered by Full Bench of this Court in Income Tax Appeal No. 348 of 2008 (Commissioner of Income Tax Vs. Muzaffar Nagar Development Authority) vide opinion dated 05.02.2015. Following substantial questions were referred to for opinion of full Bench: "(i) Whether the non disposal of an application for registration, by granting or refusing registration, before the expiry of six months as provided under Section 12AA(2) of the Income Tax Act, 1961 would result in deemed grant of registration; and (ii) Whether the Division Bench judgment of this Court in the case of Society for the Promotion of Education, Adventure Sport & Conservation of Environment vs. Commissioner of Income Tax (2008) 216 CTR (All) 167 holding that the effect of non consideration of the application for registration within the time fixed by Section 12AA(2) would be deemed grant of registration, is legally correct." 4. The same were answered by Full Bench as under: "In the circumstances, we answer the questions referred to the Full Bench for reference in the following terms: (i) Non disposal of an application for registration, by granting or refusing registration, before the expiry of six months as provided under Section 12AA (2) of the Income Tax Act 1961 would not result in a deemed grant of registration; and (ii) the judgment of the Division Bench of this Court in Society for the Promotion of Education Adventure Sport & Conservation of Environment (supra) does not lay down the correct position of law." 5. In view thereof, all the questions are answered in terms of aforesaid Full Bench judgment in Commissioner of Income Tax Vs. Muzaffar Nagar Development Authority (supra) since the decision in Society for the Promotion of Education Adventure Sport & Conservation of Environment (supra) has been overruled. 6. Appeal is allowed. Impugned judgment of Tribunal dated 27.05.2014 is hereby set aside.