The assessee trust's registration u/s 12AA was cancelled retrospectively by the CIT(E) u/s 12AB(4)(b)(i)...

The assessee trust's registration u/s 12AA was cancelled retrospectively by the CIT(E) u/s 12AB(4)(b)(i) on grounds of commercial activities, diversion of funds to related parties, and violation of Section 13(3). The key points are: The ITAT held the retrospective cancellation was incorrect as the specified violations u/s 12AB(4) were introduced prospectively from 01.04.2022 and cannot apply to earlier years. The revenue cannot re-agitate issues like commercial activities which were already decided in the assessee's favor. Cancellation cannot operate retrospectively in absence of specific provision. The CIT(E) initiated proceedings based on a reference from the AO, but no fresh reference was made after registration was granted on 23.09.2021..... .....

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