Held that in the case of the assessee, it had been held that doing business or not did not warrant the cancellation of registration the Department could not raise the issue again and there must be some finality on the issue. The observations or reasons in the order of the Commissioner (E) under challenge had no validity as the issue had already become final.   That in the absence of specific mention that the amended provisions operate retrospectively, the cancellation could not operate from a past date, in this case from the assessment year 2017-18.  That the Commissioner (Exemption) had initiated proceedings of cancellation of registration based on the reference received from the Deputy Commissioner (E) dated February 6, 2020.  There was no such reference after registration was granted on September 23, 2021. The provision for making the reference was inserted in law with effect from April 1, 2022 and at the time of reference, there was no provision for making such reference under the second proviso to section 143(3) of the Act for trusts and institutions referred to under section 11 of the Act. Therefore, the reference itself was without the authority of any statutory provisions and there is  no fresh reference by the Assessing Officer. That  the cancellation of registration under section 12AA(3) / 12AB(4) by the Commissioner (E) is  bad in law and the registration already granted to the assessee is  to be restored. (AY.2017-18)