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ITAT allowed the assessee's appeal and quashed PCIT's order cancelling 12A registration of a charitable society. The Tribunal held that show cause notices dated 05.07.2023 and 16.08.2023 were erroneous as Section 12AA(5) provisions cannot apply to orders after 01.04.2021. Similarly, PCIT's invocation of Section 12AB(4) for cancelling registration was impermissible since this provision became effective from 01.04.2022 and could not be applied retrospectively to Assessment Years 2015-16 to 2021-22. The Tribunal found the entire proceedings based on wrong legal foundation, with PCIT's order being erroneous, whimsical, arbitrary, and demonstrating bias. The direction that cancellation would continue independently even without specified violations was deemed a colourable exercise of power, establishing the authority's predetermined intent to cancel registration.
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