No Retrospective Cancellation: ITAT Rejects PCIT Action on 12A/12AB Without Section 120 Order

Sushila Devi Centre for Professional Studies and Research Vs PCIT (Central) (ITAT Dehradun)

PCIT (Central) Had No Jurisdiction to Cancel 12A/12AB Registration without sec 120 order– ITAT Quashes Retrospective Cancellation

Assessee, an educational charitable society registered u/s 12A since 2004 (renewed u/s 12AB up to AY 2026-27), was subjected to search. Thereafter, PCIT (Central), Kanpur cancelled the registration retrospectively from AY 2014-15 to 2024-25, alleging violation of section 11/12/13.

Key Legal Issue:

Whether PCIT (Centra

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