Sec. 11 & 12AA of Income Tax Act, 1961— Exemption — Merely because, in a given year, an institution, by carrying on any trade, commerce and business is in receipt of an amount in excess of Rs. 25 lakhs, would not entitle the Director of Income Tax to cancel the registration under Section 12AA(3) and the jurisdiction to cancel registration would only arise if there is any change in the nature of the activities of the institution or the activities of the institution are not genuine and in the absence of fulfillment of either of these pre-conditions, the CIT or the Director, as the case may be, will not have any jurisdiction to invoke the provisions of Section 12AA(3)—GOA INDUSTRIAL DEVELOPMENT CORPORATION Vs. CIT [2020] 421 ITR 676 (BOM)