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The ITAT allowed the assessee's appeal, holding that the Finance Act, 2022 amendment is prospective and does not apply to accumulations made prior to AY 2023-24. The Tribunal found that the sum of Rs.30,00,000 was accumulated in FY 2016-17 and utilised in FY 2022-23 within the extended timeline permitted by the pre-amendment section 11(3), therefore it could not be treated as deemed income. The adjustment by the CPC and confirmation by the CIT(A) treating the amount as income taxable under section 115BBI was unsustainable. The ITAT set aside the CIT(A) order and directed the AO to delete the addition of Rs.30,00,000 under section 115BBI.
The ITAT allowed the assessee's appeal, holding that the Finance Act, 2022 amendment is prospective and does not apply to accumulations made prior to AY 2023-24. The Tribunal found that the sum of Rs.30,00,000 was accumulated in FY 2016-17 and utilised in FY 2022-23 within the extended timeline permitted by the pre-amendment section 11(3), therefore it could not be treated as deemed income. The adjustment by the CPC and confirmation by the CIT(A) treating the amount as income taxable under section 115BBI was unsustainable. The ITAT set aside the CIT(A) order and directed the AO to delete the addition of Rs.30,00,000 under section 115BBI.
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