JUDGMENT : The petitioner is an assessee under the Income Tax Act, 1961 (hereinafter referred to as the “1961 Act”). It is a Society registered under the Societies Registration Act, 1860. The petitioner was initially granted registration under Section 12AA of the 1961 Act. According to the petitioner, a provisional registration was also granted to the petitioner under Section 12A(1)(ac)(vi)[Originally inserted by the Finance Act, 2020 with effect from June 1, 2020 but omitted with effect from June 1, 2020 and reintroduced as above by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 with effect from April 1, 2021.]of the 1961 Act for the assessment year 2022-2023 to 2024-2025. Ext.P3 is the order granting such provisional registration. The petitioner thereafter filed an application under Section 12A(1)(ac)(iii) of the 1961 Act for the regularisation of the provisional registration. That application is on record as Ext.P4. The petitioner was called upon to submit certain information for consideration of the application through Ext.P5 notice. The petitioner provided the necessary information and a personal hearing was also granted to the petitioner. Thereafter, Ext.P8 order was passed on 30.04.2024 rejecting Ext.P4 application. The petitioner is thus before this Court challenging Ext.P8 order on several grounds, including on the ground that the petitioner was not given any effective opportunity of hearing before the order was passed. 2. Ms. Divya Ravindran, the learned counsel appearing for the petitioner, would submit that the rejection of Ext.P4 application was mechanically done without considering the amendments to the bye-laws of the petitioner-Society (Ext.P7), which indicates that the objection on the ground of violation of the provisions of Explanation (d) to sub-section (4) of Section 12AB of the 1961 Act and the provisions of Section 13(1)(b) of the 1961 Act were no longer subsisting. It is submitted that the 1st respondent only considered Clauses 5(a) and 5(b) of the bye-laws of the petitioner-Society while reaching the conclusion that the petitioner was not entitled to registration. It is submitted that Clauses 5(j) and 5(k) of Ext.P7 will indicate that the charitable activities of the Society are to be extended to all sections of the society and not to any particular community, as has been found in Ext.P8 order. It is submitted that in such circumstances, Ext.P8 is liable to be set aside and the matter is to be remanded to the 1st respondent for fresh consideration. 3. It is submitted that in such circumstances, Ext.P8 is liable to be set aside and the matter is to be remanded to the 1st respondent for fresh consideration. 3. Sri. Jose Joseph, the learned Standing Counsel appearing for the Income Tax Department, refers to the statement filed in this case and also to Annexures R1A and R1B documents produced along with the statement to contend that there is absolutely no violation of the principles of natural justice. It is submitted that prior to a hearing conducted on 18.04.2024, there was a hearing conducted on 12.04.2024, on which date, the specific clauses in Ext.P7, which would show that the petitioner-Society is not entitled to registration, were pointed out to the authorised representative of the petitioner-Society and he was requested to file his objections, if any. It is submitted that, thereafter, when the matter was taken up on 18.04.2024, no materials were produced to show that the objections pointed out in the earlier hearing had been rectified by the petitioner-Society. It is submitted that in such circumstances, there is absolutely no ground made out for interference with Ext.P8 order. 4. Having heard the learned counsel appearing for the petitioner and the learned Standing Counsel appearing for the respondents, I am of the view that the petitioner has not made out any case for grant of relief. Clauses 5(a) and 5(b) of Ext.P7 (after its amendment) read as follows:- It is no doubt true that the Clauses 5 (j) and 5(k) of Ext.P7 provide as follows:- In the light of the provisions contained in Explanation (d) to sub-section (4) of Section 12AB and the provisions of Section 13(1)(b) of the 1961 Act, the inclusion of Clauses 5(j) and 5(k) of Ext.P7 does not mean that the petitioner is entitled to a registration under the provisions of Section 12AA of the 1961 Act. Section 12AB of the 1961 Act deals with the procedure for registration. Section 12AB of the 1961 Act deals with the procedure for registration. Sub-section (4) of Section 12AB of the 1961 Act reads thus:- “12AB Procedure for fresh registration xxxx xxxx xxxx (4) Where registration or provisional registration of a trust or an institution has been granted under clause (a) or clause (b) or clause (c) of sub-section (1) or clause (b) of sub-section (1) of section 12AA, as the case may be, and subsequently,— (a) the Principal Commissioner or Commissioner has noticed occurrence of one or more specified violations during any previous year; or (b) the Principal Commissioner or Commissioner has received a reference from the Assessing Officer under the second proviso to sub-section (3) of section 143 for any previous year; or (c) such case has been selected in accordance with the risk management strategy, formulated by the Board from time to time, for any previous year, the Principal Commissioner or Commissioner shall— (i) call for such documents or information from the trust or institution, or make such inquiry as he thinks necessary in order to satisfy himself about the occurrence or otherwise of any specified violation; (ii) pass an order in writing, cancelling the registration of such trust or institution, after affording a reasonable opportunity of being heard, for such previous year and all subsequent previous years, if he is satisfied that one or more specified violations have taken place; (iii) pass an order in writing, refusing to cancel the registration of such trust or institution, if he is not satisfied about the occurrence of one or more specified violations; (iv) forward a copy of the order under clause (ii) or clause (iii), as the case may be, to the Assessing Officer and such trust or institution. Explanation.—For the purposes of this subsection, the following shall mean "specified violation",— (a) where any income derived from property held under trust, wholly or in part for charitable or religious purposes, has been applied, other than for the objects of the trust or institution; or (b) the trust or institution has income from profits and gains of business which is not incidental to the attainment of its objectives or separate books of account are not maintained by such trust or institution in respect of the business which is incidental to the attainment of its objectives; or (c) the trust or institution has applied any part of its income from the property held under a trust for private religious purposes, which does not enure for the benefit of the public; or (d) the trust or institution established for charitable purpose created or established after the commencement of this Act, has applied any part of its income for the benefit of any particular religious community or caste; or (e) any activity being carried out by the trust or institution— (i) is not genuine; or (ii) is not being carried out in accordance with all or any of the conditions subject to which it was registered; or (f) the trust or institution has not complied with the requirement of any other law, as referred to in item (B) of sub-clause (i) of clause (b) of subsection (1), and the order, direction or decree, by whatever name called, holding that such non-compliance has occurred, has either not been disputed or has attained finality. xxxx xxxx xxxx ” Section 13(1)(b) of the 1961 Act reads thus:- “13. Section 11 not to apply in certain cases. xxxx xxxx xxxx ” Section 13(1)(b) of the 1961 Act reads thus:- “13. Section 11 not to apply in certain cases. (1) Nothing contained in section 11 or section 12 shall operate so as to exclude from the total income of the previous year of the person in receipt thereof xxxx xxxx xxxx (b) in the case of a trust for charitable purposes or a charitable institution created or established after the commencement of this Act, any income thereof if the trust or institution is created or established for the benefit of any particular religious community or caste; xxxx xxxx xxxx” A reading of Explanation (d) to sub-section (4) of Section 12AB as also the provisions of Section 13(1)(b) of the 1961 Act clearly indicates that even if a part of the income is specifically set apart from the benefit of any particular religious community or caste, the entity is not entitled to registration under the provisions of Section 12AA of the Act. 5. In the light of the above, no fault can be attributed to the 1st respondent for rejecting the application for registration filed by the petitioner under Section 12AA of the 1961 Act. The writ petition fails and it is accordingly dismissed.