Section 11(3) Amendments Prospective; Pre-2022 Use Not Taxable: ITAT Delhi

Foundation For Universal Responsibility of His Holiness The Dalai Lama Vs ITO (ITAT Delhi) ITAT Delhi: 115BBI Adjustment Deleted — Pre-2022 Accumulations Still Enjoy 6-Year Utilization Window In this appeal, Assessee, a trust registered u/s 12A, challenged the adjustment of ₹1,38,45,266 made by CPC u/s 143(1) treating accumulated amounts of FY 2016-17 & FY 2017-18 as deemed income u/s 115BBI on the ground of non-utilization within five years. CIT(A) upheld the adjustment by applying the amendment made by Finance Act 2022 to s.11(3)(c), which removed the sixth-year grace period. Tribuna...