https://www.taxtmi.com/caselaws?id=782034 ITAT Bengaluru held that PCIT (Central) is legally empowered to cancel a trust's registration u/s 12AA/12AB once jurisdiction is conferred through an order u/s 127, and that such cancellation powers, effective from 1.4.2022, can operate retrospectively where specified violations are found. However, for AYs 2015-16, 2016-17 and 2019-20, the Tribunal quashed the PCIT's cancellation order, holding that the AO had not formed independent "satisfaction" on specified violations before making reference under the second proviso to s.143(3). For AY 2022-23 also, the cancellation was set aside as it was based on "borrowed satisfaction" from search material rather than the AO's own evaluation. The trust's registration was restored, with merits left to be examined in assessment proceedings. en-us Tue, 04 Nov 2025 00:00:00 +0530 Fri, 21 Nov 2025 18:22:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782034 ITAT Bengaluru held that PCIT (Central) is legally empowered to cancel a trust's registration u/s 12AA/12AB once jurisdiction is conferred through an order u/s 127, and that such cancellation powers, effective from 1.4.2022, can operate retrospectively where specified violations are found. However, for AYs 2015-16, 2016-17 and 2019-20, the Tribunal quashed the PCIT's cancellation order, holding that the AO had not formed independent "satisfaction" on specified violations before making reference under the second proviso to s.143(3). For AY 2022-23 also, the cancellation was set aside as it was based on "borrowed satisfaction" from search material rather than the AO's own evaluation. The trust's registration was restored, with merits left to be examined in assessment proceedings. Case-Laws Income Tax Tue, 04 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782034