Held that the issue of validity of cancellation of registration the Tribunal had set aside the order whereby the registration of the assessee-trust under section 12AA of the Act was cancelled since inception and restored the registration granted under section 12AA of the Act. The sole ground for reopening of assessment was that the registration granted under section 12A of the Act had been cancelled since inception. The basis of reopening of the assessment now no more existed. Therefore, the assessment framed on the basis of such ground could not be sustained.(AY. 2005-06, 2006-07)
Bhai Hospital Trust v. ITO (E) (2021) 91 ITR 77 (SN) (Delhi)(Trib.)
S. 147 : Reassessment-Medical institution-Notice issued on ground registration cancelled from inception-Order cancelling registration set aside by Tribunal and registration restored-Reassessment not sustainable. [S. 10(23C)(iiiae), 12A, 12AA, 148]