TaxTMI 
TaxTMI 
2026 (9) TMI 1636
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....ements on oath and other observations of the record revealed case for cancellation of registration of assessee u/s 12A of the Income Tax Act, 1961 (hereinafter referred to as "the Act') and accordingly a show cause was issued to the assessee detailing therein the reasons for proposing cancellation of registration as well as the basis for the same as emanating from the incriminating material on record. It was seen that the assessee has prima facie made specified violations as mentioned in explanation to section 12AB(4) of the Act and has also committed violation as per section 13 of the Act, details of which are summarized as under: a) The assessee trust has siphoned off an amount of Rs. 29,67,46,946/- in cash, by inflating salary expenditure, without entering these salary refunds in regular books of accounts, and same is not applied for the objects of the trust. As the said amount is taken back by the trustees of the trust, therefore it shows that the said amount has been utilized for the personal benefit of the persons mentioned in sub-section 3 of section 13 of the Act and not for the object of the trust. b) The expenses incurred as a brokerage towards procu....
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....ecord. 4. The initiation of proceedings by the PCIT for cancellation of registration by issuance of notice u/s 12AA(3) is bad in law. 5. The learned PCIT(C) erred in cancelling the registration u/s 12A of I.T. Act 1961 with retrospective effect from 21/09/2007. 6. The PCIT has erred in cancelling the registration provisionally granted to the appellant trust on 31/05/2021 under section 12A of the Act by her order dated 16/06/2023 u/s 12AB(4) of the Act. 7. The PCIT has erred in cancelling the registration granted to the appellant trust u/s 12AA/12AB of the Act even on merit as neither the material found during the course of search nor the statements recorded on oath as referred to and relied upon by the learned PCIT, is sufficient to establish, even prima facie, that there is occurrence of one or more specified violations in the case of the appellant as specified in Explanation to Section 12AB(4) of the Act. 8. Allegations in order passed cancelling registration based on information retrieved from USB Storage device (pen drive)having no evidentry value are unjustified and bad in law. 9. Utilisation of fees for payment to career c....
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....Commissioner/Commissioner of Income tax specified in column (4) of the said Schedules or Joint Commissioners of Income-tax subordinate to them, shall exercise powers and perform the functions as stipulated in the said Act in respect of such cases or classes of cases or such persons or classes of persons, assigned to Assessing Officers subordinate to them, under section 127 of the said Act, from the date of publication of this notification;" 33. A reading of clause(b) of the Notification 70/2014(supra) conjointly with the Explanation of section 127 leaves no room for doubt as to the intention of the Legislature as to the jurisdiction to be exercised by the authorities concerned over a class of case once order u/s 127 is issued. In the instant case, once the order u/s 127(2) dated 01.12.2016 was issued by the CIT(Exemptions), Delhi transferring the case of the assessee from ACIT(E), Delhi to Central Cir-16, Delhi under the charge of Pr. CIT(Central), Delhi, by virtue of Explanation to section 127 and Notification no 70/2014, the Pr. CIT(Central), Delhi assumes the jurisdiction over the assessee for all purposes and proceedings whether pending or completed or to be commenced,....
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....over the assessee once an order u/s 127 is issued transferring the jurisdiction to AOs subordinate to him. Hon'ble Tribunal held that a harmonious and constructive interpretation of the CBDT notification No. 70/2014 and the CBDT directive dated 19.01.2024 would show that the PCIT(Central assumes the power, and is indeed obligated to perform all the functions. stipulated in the Act, over the assessee once an order u/s 127 is issued transferring the jurisdiction to Assessing Officers subordinate to him. The Tribunal further held that section 12AB(4) of the Act empowers "the Principal Commissioner or Commissioner" to cancel registration where specified violations are noticed and that the statute does not restrict this power exclusively to the Commissioner (Exemptions), the use of the general expression in the statute itself contemplates the exercise of this power by any officer of the rank of Principal Commissioner or Commissioner who has jurisdiction over the assessee, including the PCIT(Central) upon centralization under Section 127." 9. Therefore, this contention of assessee deserves to be rejected outrightly. 10. Then, second issue arises out of contention of ld....
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....sion ld. DR vide letter dated 04.08.2026 had filed written submission specially addressing queries of bench though a quite erroneously referring it as the queries raised by ld. Judicial member. Pertinent here is to put on record that queries when raised by the member leading the Bench are queries of the Bench and not of the particular member. Thus, merely for putting the records straight, these observations needed to be made part of the order. 15. As for completeness the contention of ld. DR addressing the queries raised have been taken into consideration and we find that ld. DR has primarily contended that the show cause notice is shown to be issued u/s 12AA(3) of the Act but the same is merely a typing mistake as the complete contents of the notice dated 11.10.2022 need to be taken into consideration. 16. Ld. DR has also submitted that such a contention should have been first raised before the first PCIT and cannot be raised at the first appellate stage before this Tribunal and thus there is estoppel from assessee's conduct. Ld. DR has also relied references of appellant's own reply to submit that assessee himself was aware that notice is issued u/s 12AB(4) and not u/s 12AA....
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.... the statute the provisions of section 12AB of the Act vide Finance Act 2022." This is an unambiguous and express invocation of the new section 12AB framework. (e) The impugned final order dated 16.06.2023, passed by the Pr. CIT (Central), Nagpur, consequent to the show cause notice and the assessee's response, is captioned, dated, signed, and passed under section 12AB(4) of the Act. The header of the order records "Order under section 12AB(4) of the Income Tax Act, 1961." The order in its entirety proceeds on section 12AB(4) of the Income Tax Act, 1961. 2.6. It is respectfully submitted that the show cause notice also contains, at paragraph 4.5, an isolated sentence which reads: "...it is prima facie evident...that the trust has committed specified violations detailed in 'Explanation to Section 12AA(4)' of the Act." This reference to "Section 12AA(4)" is, on a fair and holistic reading of the notice as a whole, a typographical/clerical mis-numbering and nothing more. The following submissions are made in this regard: (a) Section 12AA was omitted from the statute with effect from 01.04.2021. Even when it was in force, sub-section (4) of sectio....
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....ase against the trust. The appellant availed itself of that opportunity in full by filing a detailed reply running to multiple pages and covering each of the five violation areas enumerated in the show cause notice. The form of the document granting the opportunity of being heard is entirely subordinate to its substance. The appellant received the case against it in complete detail, understood it fully, and responded to it comprehensively. The label on the document cannot be determinative." 17. Further, ld. DR in the written submission filed has submitted as to how the decision relied by ld. Counsel for assessee are not applicable and on the contrary the decisions of the Coordinate Bench in Advantage India Vs. Pr.CIT (2025) 178 taxmann.com 605 (Delhi Tribunal) and Rukmini Educational Charitable Trust vs. PCIT (Central), Bengaluru (ITA No. 2106 to 2019/Bang/2024) were relied. Reliance is also placed in Bangaluru bench decision in Independent and Public Spirited Media Foundation Vs. PCIT (Central), Bengaluru, ITA No. 625/Bang/2023. 18. Ld. DR has then addressed the issue that the notice issued was proper and for completeness his contentions in para 4 are reproduced below: ....
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....cannot be allowed to obscure the gravity and the overwhelming weight of the evidence of violations established in this case. He has contended that the legislature, through section 12AB(4), has conferred a clear and express power upon the Principal Commissioner or Commissioner to safeguard the integrity of the charitable trust registration framework. The grant of registration is a privilege extended by the State to institutions that genuinely devote their resources to public benefit, in consideration of which substantial tax exemption is granted. Where an institution systematically abuses this privilege by diverting its funds for private benefit, using the trust as a vehicle for generating and deploying unaccounted cash and engaging in money-laundering transactions through accommodation entry networks, the withdrawal of the privilege of registration is not merely justified but is a necessary and mandatory consequence under the statute. He asserts, the impugned order correctly holds that "the pillars of charity stand demolished" in the present case. The words of the Pr. CIT (Central) reflect the reality of the situation as disclosed by the overwhelming evidence on record. The appella....
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....o individuals who do not exist. Salary was paid to individuals who are not employees and salaries paid to regular staff which was received back in cash, forms the basis of the allegation. We find that it is in the period of 2014-15 onwards till July 2021 the issue with regard to the portion salary collected back and allegedly siphoned off have been examined and made foundation and pass the impugned order. 22.3 In regard to alleged specified violation of issue of payment of brokerage in cash in the Financial Year 2014-15 to 2020-21, the year wise break-up of brokerage amount paid have been made basis to allege that this expenditure is against stated object of the trust and is therefore, specified violation in terms of Section 12AB(4) explanation. 22.4 Further, ld. PCIT has alleged that there is issue of other fees collected but not recorded in the books of accounts and in this regard particularly prospects fees collected and other fees so collected by NIT, GSM for Financial Year 2014-15 to 2020-21, became subject of examination and the allegation is that the fees collected is income of the trust but not accounted and therefore, not spent on the objects of the trust and consequ....
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....c directions. 22.9. The aforesaid discussion of the fact and allegation and the evidences relied by the ld. PCIT at the time of giving impugned notice dated 11.10.2022 and passing impugned order dated 16.06.2023, makes one thing very crystal clear that all these allegations and evidences are for a period prior to 01.04.2022. In fact, the search and seizure action u/s 132 and survey u/s 133A of the Act were undertaken on 17.09.2021 on the group including the assessee. 22.10 Thus, the foremost issue which we need to decide is if at all the provision of Section 12AB(4) of the Act, which had come into effect vide Finance Act, 2022 in regard to cancellation of registration on the basis of specified violation can at all be sustained. In this regard, we are of the considered view that provisions of Specified violation as introduced by way of Explanation to Section 12AB of the Act vide Finance Act, 2022 brings in place a complete code in itself and the consequences of the alleged violation is of penal in nature. Such penal consequences should always be taken to have come into effect prospectively and for any alleged act or omission prior to coming into effect of Finance Act, 2022 sho....
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.... or CIT shall pass an order in writing cancelling the registration of such trust or institution after affording reasonable opportunity of bearing heard for such previous year and of subsequent previous years if he is satisfied that one or more specified violation have taken place. Now the word 'specified violation' was not appearing in the original section 12AB(4) w.e.f. 01.04.2021 but there was an amendment brought into by the Finance Act, 2022 w.e.f. 01.04.2022 inserting the word 'specified violation' and its definition. Now prior to 01.04.2022, there is no mention of the word 'specified violation' with regard to cancellation of registration granted u/s.12A, 12AA and 12AB of the Act. In the instant case, the allegation made by the Revenue authorities is with regard to cash received against staff salary, doctors salary, PG stipend through bearer cheque and also receiving capitation fee in cash during the period F.Yrs. 2019-20 to F.Y. 2021-22. The 'specified violation' as referred by ld. PCIT in the impugned order relates to three financial years. However, as observed above, the word 'specified violation' has been brought into Statute from 01.04.2022. Therefore, the same could not ....
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....able cause for the activities to be carried out in the said manner." 21. Now in the above sub-section (3) and (4) of section 12AA, there is no mention to any 'specified violation' but only refers to the genuineness of the activity carried out by a trust or institution, however, ld. PCIT has only referred to some 'specified violations during F.Yrs. 2019-20 to 2021-22 which was going on under scrutiny by AO. There were only few statements which were recorded during the course of search which are the basis of the alleged allegation and that too have been retracted and apart from that no other evidence and no accounted assets, unaccounted income were found during search at assessee's premises and therefore they are merely allegations and there is no concrete finding disproving the genuineness of activities of trust. Therefore, even sub-section (3) and sub-section (4) of section 12AA could not have been invoked in absence of any specified violation for the years under consideration. 22. To conclude we allow the legal ground raised by the assessee in Ground Nos. 2 and 3 and hold that since the show cause notices issued to the assessee on 21.07.2023 and 20.03.2024 are in....
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.... objects of the trust, the cancellation of registration by invoking Section 12AA(3) was valid and permissible. None of the case laws which have been cited before us with regard to lack of power to cancel registration with retrospective effect in case of specified violations being committed have been discussed. Thus, this decision in the case of Advantage India (supra) does not benefit the department at all. 22.14 The decision in Legal Initiative for Forest and Environment, (Life Trust) (supra), cited by Learned DR is, in fact, only a decision of bench in a stay application, and certainly that does not have any persuasive value. Even in that assessee's own case, it would not have any persuasive value, where appeal is heard finally. 22.15 Coming to the decisions of the Bangalore Tribunal in the case of Independent and Public Spirited Media Foundation (supra) and Rukmani Educational and Charitable Trust (supra), the decision in Rukmini Educational Charitable Trust (supra) was first in time and has been considered in the case of Independent and Public Spirited Media Foundation case (supra). 22.16 Now, if we take into consideration the decision in Rukmani Educational Trust ....
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....well. Then the circular specifies that the new provision of Section 12AB is by the way of substitution. Thus being of penal consequences, to our mind certainly it would be prospective in its application. The circular categorically lays down that the amendments brought by the way of the substitution come into effect from 1 April 2022. Thus leaving no doubt in our mind that the retrospective application to the 'violations' found to be committed for period prior to 1st April 2022, cannot be made culpable into the scope of 'specified violations' as defined, by bringing in an amendment by the way of substitution of Section 12AB. Thus these decision relied by ld. DR, do not help the department. 23. Furthermore, on the basis of aforesaid discussion we also find from the impugned notice dated 11.10.2022 and also from the impugned order dated 16.06.2023 that ld. PCIT has made very broad allegation of assessee committing 'one or more specified violations' as specified in Explanation to Section 12 AB(4) of the Act. However, there is nothing coming up to indicate as to which specific clause, (i) to (vi) mentioned in the Explanation were invoked. 23.1 We are of the considered view that wh....
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....n institution and its activities. Thus, the provisions of the law have to be strictly interpreted and complied with. 19.1 As we take into consideration provisions and scope of 12AB(4) of the Act, we find that it refers to the powers granted for an action subsequent to grant of registration or provisional registration of a trust under section 12AA of the Act, and if, 'subsequently', specified violations are discovered, then, the competent authority is entitled to initiate an action by following a procedure enshrined in clauses (i) to (iv) of sub-section (4) of section 12AB of the Act. 19.2 It comes up that, clause (i) of sub-section (4) of section 12AB of the Act requires that the competent authority shall call for such documents or information from the trust or institution for making such inquiry as he think necessary in order to specify himself about the occurrence or otherwise of any'specified violation'. This clause (i) when read with clause (ii) of sub-section (4) of section 12AB of the Act indicates that the competent authority shall, before cancelling the registration, call for documents or information or make an inquiry as is necessary and, thereupon, after....
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....a-3.4.1 supra the trust has not complied with TOHO (Transplantation of Human Organs and Tissues) Act, 1994, because of which its license for kidney transplantation was cancelled and never renewed. Thus assessee has made violation as per Explanation (f) to 12AB(4). (v) It is amply clear from discussion in Para-3.5.1 & 3.5.2 supra the application made by trust u/s 12A(1)(ac) contains false and incorrect information. Thus assessee has made violation as per Explanation (g) to 12AB(4)." 23. The aforesaid observations of the competent authority in paras 3.7 and 3.7.1 leaves no doubt in the mind of this bench that at the time of issuance of notice on 14.03.2024 calling upon the assessee to show cause for the purpose of clause (ii) of sub-section (4) of section 12AB of the Act the competent authority has not reached any conclusion on the basis of information called from the assessee or any independent inquiry as to which of the class of 'specified violations' defined in Explanation to sub-section (4) of section 12AB of the Act are being invoked. Neither there is proposal to cancel the registration retrospectively. 24. A co-ordinate bench on which one of us, the j....
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....ification No.52/2014, S.O.2754(E) dated 22.10.2014 to hold that PCIT (Central), Gurugram does not have jurisdiction to pass order u/s 12AB(4) of the Act and not considering the CBDT Notification No.70/2014, S.O. 2915(E) dated 13.122014 according to which PCIT (Central), has very much jurisdiction to pass the aforesaid order ? (iii) As to whether PCIT would have the powers to pass an order u/s 12AB, after the jurisdiction of the case of assessee has been transferred under Section 127, which would also include all proceedings including registration ?" 25. Lastly we take note of the decision of Hon'ble Mudurai Bench of Madras High Court in M/s.S.R.Trust, Represented by its Trustee, B.Kannan versus PCIT, Chennai in W.P.(MD)No.14791 of 2021 and W.M.P.(MD)Nos.11697 and 11698 of 2021 order dated 18.08.2021 is also relevant where Hon'ble High Court has examined the scope of word 'subsequently' used in Section 12AB of the Act and has held that the words 'subsequently' occurred in Sub-Section 4 of Section 12AB shall be construed as 'subsequent to the registration under new regime. Para 33 is thus reproduced below; "33. In this context, even though an at....
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....missioner has received a reference from the Assessing Officer under the second proviso to sub-section (3) of section 143 for any previous year; or (c) such case has been selected in accordance with the risk management strategy, formulated by the Board from time to time, for any previous year, the Principal Commissioner or Commissioner shall,- (i) call for such documents or information from the trust or institution, or make such inquiry as he thinks necessary in order to satisfy himself about the occurrence or otherwise of any specified violation; (ii) pass an order in writing, cancelling the registration of such trust or institution, after affording a reasonable opportunity of being heard, for such previous year and all subsequent previous years, if he is satisfied that one or more specified violations have taken place; (iii) pass an order in writing, refusing to cancel the registration of such trust or institution, if he is not satisfied about the occurrence of one or more specified violations; (iv) forward a copy of the order under clause (ii) or clause (iii), as the case may be, to the Assessing Officer and such trust or institution. ....
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....Act. We are sure each clause would need a different sort of enquiry. Reliance for same is placed on decision in Rukmani Educational Trust (supra). Where the order of PCIT was quashed as same was found to be on borrowed satisfaction of AO. 25.1 Then, in case before us, there is no reference and without giving conclusive observation as to which one of the specified violation, i.e one or all of, clauses (i) to (f), described in Explanation to section 12AB(4) of the Act was found to have occurred, the notice is issued. 26. If we look at the provisions of section 12AB(4), it comes up that there is reference as for the purpose of invoking powers of cancellation u/s 12AB(4) of the Act, cognizance can be taken under three different mode, depending the source of information, referred in relevant clauses (a) to (c) of Section 12AB(4) of the Act. 26.1 Then clause (i) provides for inquiry and the notice issued by prescribed authority is to examine and record satisfaction, if there is occurrence of specified violations. 26.2 Once this finding and satisfaction is arrived at, then under clause (ii) notice has to be issued, calling assessee, to explain why registration should not be ca....
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....he purview of Sec. 12AB of the Act. Reliance in this regard is placed on decision of co-ordinate bench in Richmond Educational Society Versus DCIT/ ACIT, Central Circle, Ghaziabad ITA No. 4779/Del/2025 order dated 11.03.2026. Which have been relied also by Pune bench in Yashaswi Academy for Skills versus PCIT, (Central) Pune ITA No. 2814/PUN/2025 order dated 03.07.2026 and Santosh Trust Versus ACIT (Central-6), Delhi, ITA Nos. 3128& 3570/DEL/2026 order dated 31/08/2026, for the said proposition. 28. Thus mere allegations that certain transactions conferred benefit on persons referred to in section 13(3) of the Act, do not, by themselves, establish that the charitable activity is non-genuine or that the institution has abandoned its charitable object. The violations involving benefit to specified persons are dealt with by denial of exemption or taxation of the diverted income at the assessment stage and do not by themselves warrant cancellation of registration for which reliance is further placed on the decision of G.D. Education Society Versus DCIT/ACIT, Central Circle 2026(5) TMI 1776 - ITAT DELHI. 29. In the light of aforesaid discussion too we are of the considered view th....
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....unt opening application, Bank passbook of Smt. SukeshaniPatil iii. Copy of Statements of employees recorded on oath u/s 131 before the Income Tax Officer. iv. Copy of affidavits of Shri Dhiraj Thakur and Shri AvinashThakre v. Copy of affidavits of MangeshDharme and SachinLadekar vi. Copy of statement of employees submitted before learned A.O. during 12AA(3) proceedings vii. Copy of affidavit of JagdishBarange viii. Copy of affidavit of Nageshljamulwar." 33. As with regard to brokerage in cash it was submitted that detailed explanation of same was given to the ld. PCIT which had not been rebuted by any independent evidence. So were the assertion in regard to other fees which allegedly were accounted in the books. As with regard to receipt of money from other entities it was submitted that that was integral part of the activity of the assessee and has been used for the educational activities of the assessee. In this context, Hon'ble Bombay High Court decision in Vanita Vishram Trust v. Chief Commissioner of Income-tax (2010)327 ITR 121 (Bom) was relied to submit that once expenditure is incurred on the object of trust and the s....
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....ued u/s 131 of the Act, statement of such employees with regard to payment of salary was recorded on oath and the employees appearing before the ld. AO have stated on oath that they all received complete salary and nothing was refunded. 38. In regard to this assertion we find the assessee vide way of paper book volume 6 has filed a copy of letter dated 24.03.2023 written by Addl.CIT (Central Range-2) Nagpur, to the Commissioner of Income Tax (Central) Nagpur has been provided at page No. 1 which indicates that during the pendency of present proceedings before ld. PCIT, a report was called on examination/cross examination of employees/staff and vide letter dated 20.03.2023, DCIT, Central Circle 2(2) Nagpur had forwarded a report which was forwarded to ld. PCIT. Copy of this report is available at page No. 2-4 of the paper book and ld. AO conducting assessment proceedings u/s 143(3) had submitted that in the examination and cross examination of 15 employees of the trust, employees have denied return of any part of salary in cash to the trust and filed their bank accounts. The list of 15 such employees was given which includes the persons whose statement have been relied by ld. PCI....
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....d for objects of trust or institution but allegation is of receipts which are not accounted in the books. As for that act of siphoning of cash receipts specified violation cannot be attributed against the trust as an independent entity. Clause (b) to the Explanation 12AB refers to specified violation where the income has been shown to be arising out of profit and gains of business which is not incidental to the opening of its objective and separate books are not kept. This too certainly is not the allegation in the case. Similarly, clause (c) refers to application of income for private religious purposes and clause (d) refers to application of income for benefit of any particular religious community. Clause (f) and (g) are certainly not applicable at as they are technical violations. 43. Thus, what is left is clause (e) wherein specified violation have been alleged to be of the nature if any activity of the trust or institution is found to be non-genuine or is not being carried out in accordance with or any of the conditions subject to which assessee was registered. As far as the genuineness of the activities is concerned, fact that assessee is running educational institutions f....
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....tion of issues no 2 and 3 in favour of assessee the corresponding grounds are sustained and the impugned order deserves to be quashed. Accordingly the appeal is allowed. Order pronounced in the open court on 08.09.2026. ============= Document 1 METAX DEPARTMEN 121 indy refce have Document 2 It follows that this portion of fee collected is income of the trust not accounted r and therefore not spent on objects of the trust and consequently there is prima cie attraction of specified violations provided in Explaantion to Section 12AB(4) of e Act. This again calls for cancellation of registration of the trust rther, as submitted by the AO, substantial Shri Sai Shikshan Sanstha: nsferred from Fremof money have been Balcon companies namely Reliable Finance Corporation Put Itd ealcon Pvt Ltd, Utsav Securities Pvt Ltd, Sital Leasing and Finance Ltd, Avail nancial Services Ltd and Destination Texofab Pvt Ltd to Shri Sai Shikshan Sanstha Surveys u/s 133A of the Act were also conducted in the business premises of above the companies. The details of the funds transferred from the stones company aforesaid 6 megnies to Shri Sai Shikshan Sanstha are as follows; (Amount in Rs m....
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....nation provided by different individuals associated with the Delhi based companies and lagpur based shri sal skiguas Deini ubsequently to Shri Sai Shikshan \Baheti to have been transferred to Delhi verheti himself directly to Shri Sar Shikshar same funds being transferred by 9.7 The statement of Shri Nimodia contradicts with what Shri Surendra Jain Shri Sai Shikshan Sanstha from Avail Financial Services Ltd Sital Leasing nance Ltd were in the form of donations from CSR funds and SitaLeasing and Icon Pvt ltd were in the form of loans and advanav Securities Pvt Ltd and VA advances of funds transa, Shri sua based comp to Shri Sai Shikshan Sanstha. Shri Sai Shikshalation of quant es .The quantum oran amountcall salary refund collecte by brokerage paid in cash miscellaneous n cash funds nom companies Total .Y.2014-15 3,40,38,984 16,90,000 9,43,500 3,66,72,484 .Y.2015-16 23,32,500 9,41,500 4,24,51,556 Y.2016-17 4,45,05,170 32,65,000 6,69,500 formation other, it is submitted by the , was recormation in the case of Shri Sa Shikshan Sanstha for the A.Y. 2012-13 received from thethe lkata. The Kolkata A.that Shri Manfrom the Investigation win of providing a Manoha....