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of <h1>Rulings say Finance Act 2022's shortening of Section 11(3)(c) accumulation window applies prospectively to pre-1 April 2022 funds</h1> Two Tribunal benches held that the Finance Act, 2022 amendment shortening the accumulation/utilisation window under Section 11(3)(c) operates prospectively, so accumulations made before 1 April 2022 remain governed by the prior six-year regime; relying on the presumption against retrospective taxation, the Finance Bill memorandum, and precedent on retrospectivity, the tribunals disallowed taxability where funds created in FY 2016-17/2017-18 were utilised within the erstwhile sixth year. The rulings grant relief to affected trusts/institutions but leave open potential challenges by revenue to higher courts on timing and wider application.
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