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The ITAT reversed the lower authorities' disallowance of the assessee's claim for exemption under section 11 in respect of accumulated income from AY 2017-18 onwards. The Tribunal held that the statutory amendment to section 11(3)(c), effective from AY 2023-24, could not retrospectively apply to prior accumulations. The prescribed application period for accumulated funds remained unaltered for years preceding the amendment. Consequently, the Revenue's rejection of the exemption claim was found to lack merit. Relying on precedents emphasizing non-retroactivity and strict interpretation, the Tribunal allowed the assessee's appeal, restoring the exemption for income accumulated before the amended provision's operative year.
The ITAT reversed the lower authorities' disallowance of the assessee's claim for exemption under section 11 in respect of accumulated income from AY 2017-18 onwards. The Tribunal held that the statutory amendment to section 11(3)(c), effective from AY 2023-24, could not retrospectively apply to prior accumulations. The prescribed application period for accumulated funds remained unaltered for years preceding the amendment. Consequently, the Revenue's rejection of the exemption claim was found to lack merit. Relying on precedents emphasizing non-retroactivity and strict interpretation, the Tribunal allowed the assessee's appeal, restoring the exemption for income accumulated before the amended provision's operative year.
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