https://www.taxtmi.com/caselaws?id=466132 Amendment to section 11(3) introduced by Finance Act 2022 operates prospectively, with the five-year limit on application of accumulated income applying only from AY 2023-24; utilisation of accumulation in the sixth year under the pre-amendment regime is therefore permissible, and an assessment addition imposed by the CPC on that basis was deleted, resulting in allowance of the appeal. Reliance was placed on earlier decisions holding substantive amendments lacking explicit retrospective intent apply prospectively, supporting deletion of the impugned addition and vindicating pre-amendment utilisation rights. en-us Fri, 29 Aug 2025 00:00:00 +0530 Sun, 25 Jan 2026 21:24:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466132 Amendment to section 11(3) introduced by Finance Act 2022 operates prospectively, with the five-year limit on application of accumulated income applying only from AY 2023-24; utilisation of accumulation in the sixth year under the pre-amendment regime is therefore permissible, and an assessment addition imposed by the CPC on that basis was deleted, resulting in allowance of the appeal. Reliance was placed on earlier decisions holding substantive amendments lacking explicit retrospective intent apply prospectively, supporting deletion of the impugned addition and vindicating pre-amendment utilisation rights. Case-Laws Income Tax Fri, 29 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466132