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Amendment to s.11(3) Prospective: Old Accumulations Retain 6-Year Window
Case Law Details
- Case Name
- Taldhwaja Jain Swetamber Tirth Committee Vs ITO (Exemption) (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2023-24
- Courts
- All ITAT, ITAT Ahmedabad
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Taldhwaja Jain Swetamber Tirth Committee Vs ITO (Exemption) (ITAT Ahmedabad)
Amendment to Section 11(3) Prospective – Old Accumulations Still Get 6-Year Window- ITAT Ahmedabad
Assessee trust registered u/s 12AB, filed NIL return for AY 2023-24 claiming exemption u/s 11. CPC, while processing the return u/s 143(1), accepted accumulation of ₹58.62 lakh but treated ₹30 lakh, accumulated in FY 2016-17 u/s 11(2) & utilised in FY 2022-23, as deemed income taxable u/s 115BBI, relying on the amended s.11(3) inserted by Finance Act, 2022.
CIT(A) upheld CPC’s action, holding...






