https://www.taxtmi.com/caselaws?id=774249 The ITAT Ahmedabad allowed the assessee's appeal regarding utilization of accumulated trust funds. The case involved a trust that accumulated funds in F.Y. 2016-17 and utilized Rs. 2,32,073 in the additional one-year period ending F.Y. 2022-23. The CPC disallowed the claim citing Finance Act 2022 amendment removing the additional year provision from Section 11(3). The ITAT held that applying the amendment retrospectively would create an impossible situation under the doctrine of impossibility (lex non cogit ad impossibilia), as the assessee would have no time to utilize already accumulated funds. The tribunal emphasized that legal provisions should be interpreted with practicality and reasonableness, not rigidly when leading to unfair outcomes. en-us Thu, 03 Jul 2025 00:00:00 +0530 Sat, 05 Jul 2025 08:47:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774249 The ITAT Ahmedabad allowed the assessee's appeal regarding utilization of accumulated trust funds. The case involved a trust that accumulated funds in F.Y. 2016-17 and utilized Rs. 2,32,073 in the additional one-year period ending F.Y. 2022-23. The CPC disallowed the claim citing Finance Act 2022 amendment removing the additional year provision from Section 11(3). The ITAT held that applying the amendment retrospectively would create an impossible situation under the doctrine of impossibility (lex non cogit ad impossibilia), as the assessee would have no time to utilize already accumulated funds. The tribunal emphasized that legal provisions should be interpreted with practicality and reasonableness, not rigidly when leading to unfair outcomes. Case-Laws Income Tax Thu, 03 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774249