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    <title>2026 (4) TMI 1395 - ITAT MUMBAI</title>
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    <description>An amendment governing utilisation of charitable accumulation under section 11(3) could not be applied to past accumulations made under section 11(2) where the right to utilise the amount had already accrued under the earlier regime. Accumulated income set aside in assessment year 2017-18 was held capable of being applied in assessment year 2023-24, because the Finance Act, 2022 amendment could not retrospectively defeat that vested entitlement and the truncated compliance window left no real opportunity to meet the new condition. The addition under section 11(3) was therefore deleted and the assessee&#039;s use of the accumulated income in the later year was upheld.</description>
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    <pubDate>Mon, 20 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (4) TMI 1395 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=790326</link>
      <description>An amendment governing utilisation of charitable accumulation under section 11(3) could not be applied to past accumulations made under section 11(2) where the right to utilise the amount had already accrued under the earlier regime. Accumulated income set aside in assessment year 2017-18 was held capable of being applied in assessment year 2023-24, because the Finance Act, 2022 amendment could not retrospectively defeat that vested entitlement and the truncated compliance window left no real opportunity to meet the new condition. The addition under section 11(3) was therefore deleted and the assessee&#039;s use of the accumulated income in the later year was upheld.</description>
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      <pubDate>Mon, 20 Apr 2026 00:00:00 +0530</pubDate>
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