ITAT allowed the appeal of a charitable entity challenging...

ITAT allowed the appeal of a charitable entity challenging denial of exemption under section 11. The assessee accumulated funds during FY 2016-17 and utilized them in the sixth year (FY 2022-23). CPC treated the unutilized amount as deemed income in AY 2023-24. ITAT held that since utilization occurred before 31.03.2023, within the year immediately following the prescribed five-year period, and amendments to section 11(3) were prospective, taxation was improper. The tribunal ruled that if taxation was warranted, it should have occurred in AY 2022-23 when the five-year period expired on 31.03.2022, not in AY 2023-24. ITAT set aside the lower authority's order and directed deletion of the adjustment, allowing the assessee's grounds.