This appeal by assessee is directed against order of Director of IT (Exemptions), Chennai, passed under s. 12AA of IT Act, 1961. solitary issue raised in this appeal relates to question as to whether Director of IT (Exemptions), Chennai, was correct in allowing registration to assessee w.e.f. 13th March, 2000 and not since its inception. We have heard rival submissions in light of material placed before u s and precedents relied upon. assessee is association. It filed application in form No. 10A on 21st March, 1994 before Director of IT (Exemptions), Chennai. On perusal of memorandum and bye-laws of association, it was found that association was formed for purpose of protection of interests of traders and business associates who were its members. This was not construed to be charitable activity. As such registration was denied to assessee. Thereafter assessee got its objects modified by resolution passed on 13th March, 2000. According to modified objects, association would strive to promote interests of trade not just interests of its members as was case before amendment. assessee did make fresh application for registration on 30th March, 2000. It was prayed that registration should be made effective from date of creation of association, namely 28th Feb., 1992. Shri V. Ramachandran, learned counsel for assessee, vehemently argued before us that objective of association all through was to promote interests of trade. Almost, all traders who mattered in this line of business were members of this association. As such they represented trade as whole. This was position even prior to modification in object. purpose of amendment was just to clarify matter and to remove cobwebs of doubts. By making classificatory amendment, doubt regarding t h e charitable objective got removed. In view of this, assessee should be registered not merely prospectively but from date of its inception. Shri K. Srinivasan, learned Departmental Representative, vehemently opposed contention raised by learned counsel for assessee. It was stated that trade itself is different from traders. There may be occasions when interests of traders may run counter to interests of trade. Persons carrying on trade at given time may individually, or even collectively, have interests at variance with long-term interests of trade itself. Hence, it is not possible to identify trader with that of trade. It is, therefore, necessary that distinction should be made between interests of traders and interests of trade itself. At time of inception objects contained in memorandum were found not to be charitable objects. As such amendment was prompted for sake of availing benefit of s. 11. It was further stated that application filed by assessee for registration on 21st March, 1994 was rejected. No remedial measure was taken against such rejection. order of rejection as such has become final. assessee did file fresh application which was considered and on basis of modified objects, registration was granted from date objects were modified, i.e., 13th March, 2000. As such there is no cause for grievance to assessee. Up till 31st March, 1997, there was no specific provision for processing of application for registration made under s. 12AA of Act and for granting or refusal of registration to concerned trust or institution. To fill up such gap, s. 12AA was inserted by Finance (No. 2) Act, 1996. It lays down procedure to be followed for grant or refusal of registration. By virtue of provision of cl. (b) of s. 12AA(1), after authority concerned is satisfied about objects of trust or institution and genuineness of its activities, he shall pass order in writing granting registration to trust or institution. However, if such authority is not satisfied, in that eventuality also order in writing needs to be passed and communicated to applicant. Principles of natural justice were also inducted inasmuch as opportunity was provided to applicant of being heard. section further stipulates time-limit of 6 months for adjudicating matter. In case CIT vs. Kamla Town Trust (1996) 130 CTR (SC) 112: (1996) 217 ITR 699 (SC), Hon ble Supreme Court held that rectification brought about in instrument of trust by order of Civil Court had no retrospective effect and would operate prospectively from date on which such rectification was effected. It was further clarified that order of rectification of instrument of trust by civil Court would not be judgment in rem. It would be judgment in personam binding on parties to rectified instrument, namely, settlor on one hand and trustees on other, as well as on ultimate beneficiaries. fact that assessee at its own made rectification in objects to avail benefit of s. 11 clearly manifests that objects at time of inception of institution were not for charitable purposes. On rejection of registration application, assessee instead of contesting order decided to modify objects so as to avail benefit of s. 11. Such modification is to be applied prospectively. There is no evidence that de hors objects for charity assessee indulged in charitable activities. Learned counsel for assessee could not demonstrate how assessee was involved in furthering objects of charity. Benefit was extended when objects germane to purposes of charity were incorporated in trust deed. modified objects cannot be applied retrospectively. These are to be applied only prospectively. As such, Director of IT, Chennai, was correct in granting registration to assessee with effect from 13th March, 2000, i.e., subsequent upon modification of objects. We do not find any merit in arguments of learned counsel for assessee that effect should be given retrospectively. Accordingly, we uphold impugned order. In result, appeal of assessee stands dismissed. *** TAMILNADU LEATHER TANNERS EXPORTERS & IMPORTERS ASSOCIATION v. ASSISTANT DIRECTOR OF INCOME TAX (EXEMPTIONS)