Accumulated charitable funds utilization timeline: amendment applied prospectively, existing accumulations retain six-year window, relief granted

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....Amendment to accumulation rules by Finance Act, 2022 prescribes utilisation of accumulated charitable funds within five years of accumulation; however, the amended provisions operate prospectively and do not curtail pre-existing six-year windows for accumulations arising before 1 April 2022. The tribunal applied the doctrine of impossibility to hold that income accumulated in financial year 201617 remained governed by the earlier six-year timeframe, precluding disallowance for the impugned assessment year. The assessees appeal was allowed and fresh accumulations from 1 April 2022 are subject to the new five-year requirement.....