https://www.taxtmi.com/caselaws?id=779185 ITAT (Ahmedabad) held that the Finance Act, 2022 amendment to s.11(3)/s.115BBI is prospective and does not apply to accumulations made before AY 2023-24. Since the assessee accumulated Rs.30,00,000 in FY 2016-17 and utilised it in FY 2022-23 within the extended time under pre-amendment s.11(3), the amount cannot be treated as deemed income or taxed under s.115BBI. The tribunal set aside the CIT(A) order, deleted the Rs.30,00,000 addition, and allowed the appeal, directing the AO to give effect to the order. en-us Wed, 24 Sep 2025 00:00:00 +0530 Tue, 30 Sep 2025 08:30:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779185 ITAT (Ahmedabad) held that the Finance Act, 2022 amendment to s.11(3)/s.115BBI is prospective and does not apply to accumulations made before AY 2023-24. Since the assessee accumulated Rs.30,00,000 in FY 2016-17 and utilised it in FY 2022-23 within the extended time under pre-amendment s.11(3), the amount cannot be treated as deemed income or taxed under s.115BBI. The tribunal set aside the CIT(A) order, deleted the Rs.30,00,000 addition, and allowed the appeal, directing the AO to give effect to the order. Case-Laws Income Tax Wed, 24 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779185