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    <title>2026 (3) TMI 790 - ITAT LUCKNOW</title>
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    <description>Section 12AA registration cannot be cancelled retrospectively without express statutory authority or allegations of fraud. Retrospective revocation was considered unsustainable where it relied on original assessment findings that had been set aside and remanded for fresh assessment. Fresh assessments accepted the trust&#039;s reconciliations regarding alleged inflated receipts and did not independently establish capitation fees or prohibited benefit under section 13(1)(c). Cancellation also required an independent application of mind rather than a derivative reliance on nullified assessments. The registration was restored with consequential benefits, as retrospective cancellation would disturb completed transactions and long-standing charitable status.</description>
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      <description>Section 12AA registration cannot be cancelled retrospectively without express statutory authority or allegations of fraud. Retrospective revocation was considered unsustainable where it relied on original assessment findings that had been set aside and remanded for fresh assessment. Fresh assessments accepted the trust&#039;s reconciliations regarding alleged inflated receipts and did not independently establish capitation fees or prohibited benefit under section 13(1)(c). Cancellation also required an independent application of mind rather than a derivative reliance on nullified assessments. The registration was restored with consequential benefits, as retrospective cancellation would disturb completed transactions and long-standing charitable status.</description>
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