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ITAT allowed the assessee's appeal, invalidating the trust registration cancellation. The tribunal found critical legal defects in the Assessing Officer's (AO) reference, including: (1) retrospective application of Finance Act, 2022 provisions to AY 2021-22, (2) reliance on seized search materials without independent verification, and (3) drawing presumptions without providing the assessee an opportunity to rebut. The ITAT held that the AO's satisfaction was procedurally flawed and based on "borrowed satisfaction," rendering the registration cancellation order legally unsustainable. The tribunal emphasized that mere possession of incriminating documents does not automatically establish wrongdoing without substantive corroborative evidence.
ITAT allowed the assessee's appeal, invalidating the trust registration cancellation. The tribunal found critical legal defects in the Assessing Officer's (AO) reference, including: (1) retrospective application of Finance Act, 2022 provisions to AY 2021-22, (2) reliance on seized search materials without independent verification, and (3) drawing presumptions without providing the assessee an opportunity to rebut. The ITAT held that the AO's satisfaction was procedurally flawed and based on "borrowed satisfaction," rendering the registration cancellation order legally unsustainable. The tribunal emphasized that mere possession of incriminating documents does not automatically establish wrongdoing without substantive corroborative evidence.
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