Trust’s Accumulation Period Cannot Be Shortened Due to Prospective Section 11 Amendment

National Foundation for Corporate Governance Vs ITO (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal Delhi concerned the taxability of a trust’s accumulated income and the applicability of amended provisions of Sections 11(2) and 11(3) of the Income-tax Act, 1961 for Assessment Year (AY) 2023–24. The assessee is a charitable trust registered under Sections 12A and 80G, claiming exemption under Section 11 since inception. Its return for AY 2023–24 was processed under Section 143(1) by the Centralized Processing Centre (CPC), which observed that the assessee had accumulated...