ITAT restores trust registration, limits PCIT power under sections 12AA, 12AB and 143(3) to valid references only

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....ITAT held that, pursuant to s.127 and relevant notifications, PCIT (Central) is legally empowered to cancel registration u/s 12AA/12AB earlier granted by CIT(E), and CIT(E) has no such power once jurisdiction is transferred. However, relying on judicial consensus that the 1.4.2022 amendment applies prospectively from AY 2022-23, ITAT ruled that cancellation u/s 12AB(4) for AYs 2015-16, 2016-17 and 2019-20 is invalid and quashed those orders. For AY 2022-23, although the provision was in force, ITAT held that the AO's "satisfaction" under the second proviso to s.143(3) must be independent and cannot rest on "borrowed satisfaction" from search material alone; the reference was thus invalid, rendering the PCIT's cancellation order unsustainable. Registration u/s 12AA/12AB stands restored for all years, with merits to be examined independently in assessment.....