The assessee, a charitable trust, utilized the accumulated income of FY 2016-17 and claimed exemption under section 11. The Assessing Officer taxed the amount relying on the amended section 11(3)(c) restricting accumulation to five years. Tribunal held that the amendment by the Finance Act, 2022, effective from 1-4-2023, is prospective and applies only to fresh accumulations from AY 2023-24 on wards. For earlier accumulations, including FY 2016-17, the assessee had time up to 31-3-2023 to utilize the income. Hence, no addition could be made, as the assessee remained governed by the earlier six-year window. (ITA No. 261/Ahd/2025 dated 02/09/2025) (AY. 2023-24)