Section 11 Exemption Preserved: Old Accumulations Utilised Within 6 Years Not Taxable

Jain Swetamber Murtipujak Tap Gachhya Upashrya Vs ITO (Exemption) (ITAT Ahmedabad) Finance Act 2022 Amendment to Sec. 11(2)/11(3)(c) Held Prospective — Trust Entitled to 6-Year Window for Old Accumulations; CPC’s Addition of ₹6.75 Lakh Reduced to ₹90,000 In this appeal, a Jain religious trust challenged the intimation u/s 143(1) where CPC taxed ₹6,75,000/– invoking amended section 11(2)/11(3)(c), treating the earlier accumulation for FY 2017-18 as lapsed & unutilised. The Trust had filed Form 10 in FY 2017-18 for accumulation of ₹6,75,000/– and utilised ₹5,85,000/– duri...