Assessment Reopening Invalid: Trust Registration Active, AO Misinterpreted CBDT Circular on Section 12A(2) Provisos' Retrospective Application.

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....Validity of reopening of assessment - non-registration of trust - registration certificate was in operation at the time the notices u/s 148 were issued - AO has not properly understood the binding circular issued by CBDT, which clearly explains the meaning of provisos inserted in sec.12A(2) of the Act. Accordingly these provisos shall have retrospective operation. - AT....