https://www.taxtmi.com/caselaws?id=466115 Finance Act, 2022 reduces maximum permissible accumulation period from ten years to five years effective 01.04.2023; this amendment is substantive and not curative or clarificatory, so it operates prospectively and cannot be applied to prior accumulations for taxability. Reliance on recent tribunal and Supreme Court principles supports prospective operation where legislative intent for retrospection is absent. Consequently, taxation of accumulated surplus claimed within the previously permissible period is not sustainable, and the assessees challenge succeeds. en-us Thu, 14 Aug 2025 00:00:00 +0530 Sat, 24 Jan 2026 11:54:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466115 Finance Act, 2022 reduces maximum permissible accumulation period from ten years to five years effective 01.04.2023; this amendment is substantive and not curative or clarificatory, so it operates prospectively and cannot be applied to prior accumulations for taxability. Reliance on recent tribunal and Supreme Court principles supports prospective operation where legislative intent for retrospection is absent. Consequently, taxation of accumulated surplus claimed within the previously permissible period is not sustainable, and the assessees challenge succeeds. Case-Laws Income Tax Thu, 14 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466115