Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT held that accumulated income under s.11(2) pertaining to F.Y. 2016-17 remained subject to the pre-amendment six-year utilization window, enabling the appellant trust to utilize such amounts until 31-03-2023. The Finance Act, 2022 amendment was construed prospectively and does not deprive existing accumulations of the benefit of the earlier temporal regime; it applies only to accumulations relating to previous years commencing on or after 01-04-2022. Consequently, no addition can be made in the impugned assessment year in respect of 2016-17 accumulations, since the appellant is governed by the law and time-limit prevailing at the relevant time.
ITAT held that accumulated income under s.11(2) pertaining to F.Y. 2016-17 remained subject to the pre-amendment six-year utilization window, enabling the appellant trust to utilize such amounts until 31-03-2023. The Finance Act, 2022 amendment was construed prospectively and does not deprive existing accumulations of the benefit of the earlier temporal regime; it applies only to accumulations relating to previous years commencing on or after 01-04-2022. Consequently, no addition can be made in the impugned assessment year in respect of 2016-17 accumulations, since the appellant is governed by the law and time-limit prevailing at the relevant time.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
