Reassessment notice issued  under section 148 of the Act dated September 28, 2018, and the registration date was September 29, 2018. This implied that the assessment proceedings for earlier years were pending before the Assessing Officer as of the date of such registration. Hence, the provisions of sections 11 and 12 of the Act would apply to income held by the assessee-trust of any assessment year preceding the assessment year in which the registration was granted. According to the Central Board of Direct Taxes Circular No. 1 of 2015 (2015) 371 ITR 22(St)  that the reassessment proceeding is  bad in law as it was contrary to the proviso to section 12A(2) of the Act hence quashed. (AY.2012-13 to 2017-18)