MUMBAI, Nov. 15 -- The dispute over the cancellation of registration of six Tata Trusts is set to be a protracted legal battle, as the trusts and tax officials differ over the end date of the registration, and whether it was a cancellation or a surrender.

While the charitable trusts said they surrendered their registration in February 2015, the tax department, which cancelled the registration in October 2019, said that there was no legal provision for surrendering the registration.

Also, if October 2019 is taken to be the end of the registration, the tax department can demand much higher tax from the trusts, because the Income Tax Act (I-T Act) did not permit taxing "accreted income" before 2016. Accreted income refers to the value by whi...