The question before the High Court was whether the registration once granted under section 12AA of the Act could be cancelled of the same set of provisions of the Trust which were examined earlier. Court held that cancellation of registration on the same provisions in the trust deed is not valid. Court also held that the Tribunal had clearly travelled not only beyond the show-cause notice but, also the order passed by the Commissioner (E). In an earlier proceeding pertaining to the year 2013-14, the Tribunal had clearly held that the trust deeds were not relevant for allowing the benefit of exemption and the income derived from the transfer of property was as per the objects of the trust. The Central Board of Direct Taxes Instruction No. 883-CBDT F. N. 180/54/72-IT (AI) dated September 24, 1975, stated that the investment of net consideration received on the transfer of a capital asset in fixed deposit with a bank for a period of six months or above would be regarded as utilization of the net consideration for acquiring another capital asset within the meaning of section 11(1A) of the Income-tax Act. Admittedly, the assessee-trust had deposited the sale proceeds in fixed deposit with the bank for a period of more than six months and, thus, it could not be said that the assessee-trust had utilised the sale proceeds contrary to the objects of the trust. The cancellation of registration was not valid.