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The ITAT allowed the assessee's appeal, holding that the amendment to section 11(3) introduced by the Finance Act, 2022 is prospective and does not affect accumulated income relating to FY 2016-17 and FY 2017-18. The Tribunal observed that the assessee utilized Rs. 35,66,540 within the prescribed six-year period for FY 2016-17, and the remaining unutilized amount was voluntarily offered in the return, thus disallowing taxation of this income in AY 2023-24. For FY 2017-18, the assessee retains the time window until 31-03-2024 to utilize the accumulated income, precluding taxation in the impugned year. The Tribunal set aside the additions of Rs. 35,66,540 and Rs. 40,00,000 related to FYs 2016-17 and 2017-18 respectively, affirming that the Finance Act, 2022 amendments apply only to fresh accumulations post 1st April 2022.
The ITAT allowed the assessee's appeal, holding that the amendment to section 11(3) introduced by the Finance Act, 2022 is prospective and does not affect accumulated income relating to FY 2016-17 and FY 2017-18. The Tribunal observed that the assessee utilized Rs. 35,66,540 within the prescribed six-year period for FY 2016-17, and the remaining unutilized amount was voluntarily offered in the return, thus disallowing taxation of this income in AY 2023-24. For FY 2017-18, the assessee retains the time window until 31-03-2024 to utilize the accumulated income, precluding taxation in the impugned year. The Tribunal set aside the additions of Rs. 35,66,540 and Rs. 40,00,000 related to FYs 2016-17 and 2017-18 respectively, affirming that the Finance Act, 2022 amendments apply only to fresh accumulations post 1st April 2022.
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