Profiteering in construction services for failure to pass input tax credit resulted in repayment exceeding the commensurate benefit and closure of pro...
Amendment to accumulation rules by Finance Act, 2022 prescribes utilisation of accumulated charitable funds within five years of accumulation; however, the amended provisions operate prospectively and do not curtail pre-existing six-year windows for accumulations arising before 1 April 2022. The tribunal applied the doctrine of impossibility to hold that income accumulated in financial year 201617 remained governed by the earlier six-year timeframe, precluding disallowance for the impugned assessment year. The assessees appeal was allowed and fresh accumulations from 1 April 2022 are subject to the new five-year requirement.
Amendment to accumulation rules by Finance Act, 2022 prescribes utilisation of accumulated charitable funds within five years of accumulation; however, the amended provisions operate prospectively and do not curtail pre-existing six-year windows for accumulations arising before 1 April 2022. The tribunal applied the doctrine of impossibility to hold that income accumulated in financial year 201617 remained governed by the earlier six-year timeframe, precluding disallowance for the impugned assessment year. The assessees appeal was allowed and fresh accumulations from 1 April 2022 are subject to the new five-year requirement.
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