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    <title>Charitable entity wins appeal against improper taxation of accumulated funds under section 11</title>
    <link>https://www.taxtmi.com/highlights?id=89807</link>
    <description>ITAT allowed the appeal of a charitable entity challenging denial of exemption under section 11. The assessee accumulated funds during FY 2016-17 and utilized them in the sixth year (FY 2022-23). CPC treated the unutilized amount as deemed income in AY 2023-24. ITAT held that since utilization occurred before 31.03.2023, within the year immediately following the prescribed five-year period, and amendments to section 11(3) were prospective, taxation was improper. The tribunal ruled that if taxation was warranted, it should have occurred in AY 2022-23 when the five-year period expired on 31.03.2022, not in AY 2023-24. ITAT set aside the lower authority&#039;s order and directed deletion of the adjustment, allowing the assessee&#039;s grounds.</description>
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    <pubDate>Thu, 26 Jun 2025 08:35:32 +0530</pubDate>
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      <title>Charitable entity wins appeal against improper taxation of accumulated funds under section 11</title>
      <link>https://www.taxtmi.com/highlights?id=89807</link>
      <description>ITAT allowed the appeal of a charitable entity challenging denial of exemption under section 11. The assessee accumulated funds during FY 2016-17 and utilized them in the sixth year (FY 2022-23). CPC treated the unutilized amount as deemed income in AY 2023-24. ITAT held that since utilization occurred before 31.03.2023, within the year immediately following the prescribed five-year period, and amendments to section 11(3) were prospective, taxation was improper. The tribunal ruled that if taxation was warranted, it should have occurred in AY 2022-23 when the five-year period expired on 31.03.2022, not in AY 2023-24. ITAT set aside the lower authority&#039;s order and directed deletion of the adjustment, allowing the assessee&#039;s grounds.</description>
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      <pubDate>Thu, 26 Jun 2025 08:35:32 +0530</pubDate>
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