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2025 (7) TMI 1496 - AT - Income TaxAssessment of trust - Disallowing the claim being unspent amount out of accumulation of FY 2016-17 - HELD THAT - When the funds were accumulated and set apart the prescribed time for utilisation of the amount was within a period of five years or in the year immediately following the prescribed period of five years and therefore for the case under consideration where the amount was accumulated during F.Y. 2016-17 assessee had time to apply the accumulated funds for charitable purposes upto 31.03.2024 i.e. A.Y. 2024-25. Therefore ld.CIT(E) erred in confirming the action of CPC making the addition for the year under appeal for A.Y. 2023-24. Finding of ld.CIT(E) is set aside and the impugned addition is hereby deleted. Grounds of appeal raised by the assessee are allowed. ISSUES:
RULINGS / HOLDINGS:
RATIONALE:
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