Reassessment based solely on prior trust non-registration fails after registration, leaving revision without a valid jurisdictional foundation.

A jurisdictional defect in a foundational reassessment may be examined in collateral revision proceedings because a void assessment cannot support revisionary jurisdiction. The third proviso to Section 12A(2), applicable from 1 June 2020, bars reassessment for an earlier assessment year solely due to a trust's non-registration once registration has been granted. Where the reassessment notice was issued after registration and rested only on prior non-registration, the reassessment was treated as void ab initio, rendering the revision order without jurisdiction.

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Issues: Whether the validity of a reassessment order may be examined in an appeal against a revision order, and whether revision can be exercised over a reassessment initiated solely because a trust lacked registration after registration had been granted.

Analysis: A jurisdictional defect in the foundational assessment may be raised in collateral revision proceedings because a void assessment cannot furnish a valid basis for assumption of revisionary jurisdiction. The third proviso to Section 12A(2), applicable from 01.06.2020, prohibits reassessment for a preceding assessment year solely on the ground of non-registration where registration has been granted to the trust. The reassessment notice was issued after the trust had obtained registration, and the recorded basis was its prior non-registration.

Conclusion: The reassessment was void ab initio, and the revision order founded on that invalid reassessment was without jurisdiction and was quashed in favour of the assessee.

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