The Assessee trust registered u/s. 12A in year 1976 sought cancellation of registration u/s.12A in 2015 which was eventually granted in 2019 due to reasons not attributable to assessee. Claimed that it surrendered its registration and, therefore, should not be treated as registered charitable trust, for application of s. 11 tax exemption, with effect from AY 2015-2016. However, revenue authorities submitted that since registration was cancelled vide Pr. Commissioner’s formal order, such cancellation will only have a prospective effect, and, accordingly, trust was required to be treated as a registered trust, for application of section 11 tax exemption, for assessment years 2015-16, 2016-17, 2018-19 and 2019-20, as also assessment year 2020-21. Held that, registration having been obtained u/s. 12A was in nature of a benefit to assessee, and if it did not wish to avail that benefit for some reason, benefit could not be forced upon him. Therefore, assessee trust’s voluntary surrender of registration u/s.12A was to be effective from date on which hearing on first show-cause notice proposing to cancel/withdraw trusts registration u/s. 12A was concluded.