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2026 Supreme(Online)(ITAT) 3714

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
MADHUMITA ROY, Judicial Member, NAVEEN CHANDRA, Accountant Member
Little Pearl Charitable Society – Appellant
Versus
PCIT (Central)-3 – Respondent


Advocates:
For the Appellants/Petitioners: Pranav Yadav, vibhu Gupta
For the Respondents: Shrikant Namdeo

Table of Content
1. appeal against retrospective 12a registration cancellation. (Para 1 , 2)
2. society's registration history and charitable objects. (Para 3 , 4 , 5)
3. search findings, centralization, and pcit cancellation order. (Para 6 , 7 , 8 , 9 , 10 , 11)
4. section 12ab(4) prospective; no retrospective cancellation. (Para 12 , 13 , 14)
5. appeal allowed; registration restored. (Para 15)

ORDER

PER Ms. MADHUMITA ROY, JM:

The instant appeal, filed by the assessee, is directed against the order dated 30.12.2024 passed by the Principal Commissioner of Income-tax (Central)-3, Delhi, under Section 12A r.w.s. 12AA & 12AB(4) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), for the Assessment Year 2013-14.

2. Grounds of appeal raised by the assessee read as under:

“1. That the learned Pr. Commissioner of Income Tax(Central)-3, Delhi has erred in law and on facts in withdrawn registration U/s 12A r.w.s. 12AA and 12AB of Income Tax Act, 1961 retrospectively from the F.Y. 2012-13 i.e. relevant to A.Y. 2013-14 and further year is bad in eye of the law. As stated in judgment of hon'ble Supreme Court of India in case of Principal Commissioner of Income-tax (Central) V. Centre For

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