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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.
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