“Section 11(3)(c)”

Section References (mined)Section 11Section 11(3)(c)39 judgments

NAVALMAL FIRODIA MEMORIAL HOSPITAL TRUST,PUNE vs. INCOME TAX OFFICER, EXEMPTION WARD 1(2), PUNE

In the result, the appeal filed by the assessee is allowed

ITA 2460/PUN/2025[2023-24]Status: DisposedITAT Pune10 Feb 2026AY 2023-24

Bench: the learned CIT(A), the same has neither been taken note of or distinguished in any manner. Not following the binding Judicial precedent of the Jurisdictional ITAT Pune is gross impropriety in law. Ground No. 2: The Appellant craves leave to add, alter, amend or withdraw all or any of the Grounds of Appeal herein and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing.”

For Appellant: Shri Shrenik GandhiFor Respondent: Shri Manish Sinha (Virtual)

Section 11Section 11(2)(a)Section 11(3)Section 11(3)(c)Section 12ASection 143(1)

clause (c) of Section 11(3) r.w.s 115BBI of the Act. b) The learned CIT-A and CPC grossly misinterpreted the provisions of Section 11(3)(c) of the Act by restricting the time limit to five years for spending the accumulated fund, instead of six years from ... years period expires in AY 2013-14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) of the Act, the sum accumulated and which remains unspent for charitable purposes, shall be deemed to be income of the person

GREEN MUMBAY LIONS EDUCATION TRUST,NA vs. ARIVS.EXEMPTION WARD, SURAT, INCOME-TAX OFFICE SURAT

In the result, appeal of the assessee is allowed for statistical purposes

ITA 547/SRT/2025[2023-24]Status: DisposedITAT Surat23 Dec 2025AY 2023-24

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.547/Srt/2025 Assessment Year: (2023-24) (Hybrid Hearing) Green Mumbay Lions Education Vs. Ito, Trust, Exemption Ward, Opp – Ratnakar Society, C/O Sgm Surat Shiroya English School, Chhapra Road, Navsari - 396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aatg8361Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Bhupendra Shah, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 12/11/2025 Date Of Pronouncement 23/12/2025

Section 10Section 11Section 11(2)(a)Section 11(3)Section 11(3)(c)Section 143Section 143(1)Section 143(1)(a)Section 154Section 234A

Rs.43,78,993/-. The appellant submitted that the unused fund can be used in the sixth year as per the provisions of section 11(3)(c) of the Act. However, the AO, CPC considered it as income for AY 2023-24. The CIT(A) referred to the amended provisions ... supra) and Shri Taldhwaja Jain Swetamber Tirth Committee (supra). The ITAT, Mumbai in case of Dadar Digamber Jain (supra) held that amendment to section 11(3)(c) by the Finance Act, 2022 w.e.f. 01.04.2023, which omitted extra period of one year following expiry of initial period of accumulation of five

NATIONAL FOUNDATION FOR COPORATION GOVERNANCE,DELHI vs. ITO WARD-2(4), DELHI

In the result, the appeal filed by the assessee is allowed

ITA 3462/DEL/2025[2023-24]Status: DisposedITAT Delhi22 Dec 2025AY 2023-24

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarnational Foundation For Corporate Governance, Vs. Ito, Ward 2 (4), C/O Confederation Of Indian Industry, Delhi. The Mantosh Sondhi Centre, 23, Institutional Area, Lodhi Road, New Delhi – 110 003. (Pan : Aaatn7649E) (Appellant) (Respondent) Assessee By : Ms. Ekta Mumari, Advocate Revenue By : Shri Dheeraj Kumar Jaiswal, Sr. Dr Date Of Hearing : 30.09.2025 Date Of Order : 22.12.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Addl / Jcit (A)–7, Kolkata [“Ld. Jcit(A)”, For Short] Dated 01.04.2025 For The Assessment Year 2023-24 Raising Following Grounds Of Appeal :- “1. That The Ld. Cit (A) Has Erred In Disposing The Appeal Against The Principles Of Natural Justice. 2. That The Ld. Cit (A) Has Erred In Law By Passing A Non- Speaking Cryptic Order Against The Principles Of Natural Justice.

For Appellant: Ms. Ekta Mumari, AdvocateFor Respondent: Shri Dheeraj Kumar Jaiswal, Sr. DR

Section 11Section 11(2)Section 11(2)(a)Section 11(3)Section 12ASection 143(1)

lakhs pertaining to financial years 2016-17 and 2017-18 respectively. The Assessing Officer noted that as per amended provisions of section 11(3)(c) of the Act, accumulation period was limited to five years and, thus, he brought said amount to tax as income of assessee. The ITAT held ... that amendment to 7 section 11(3)(c) by Finance Act, - 6– ITA No. 929/Ahd/2025 Sarangpur Talia’s Pole Punch Trust vs. ITO(E) Asst.Year –2023-24 2022 with effect from 1-4-2023 which omitted extra period of one year following expiry of initial period of accumulation of five

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, SECTOR 17

In the result, this appeal of the Assessee stands dismissed

ITA 339/CHANDI/2023[2018-2019]Status: DisposedITAT Chandigarh10 Dec 2025AY 2018-2019

For Appellant: \nSh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 263

allowing appropriate relief in\nregard to the addition of the sum of\nRs.1,58,34,30,328 made under section 11(3)(c). The\norder has been passed without considering the facts\nof the appellant and is illegal and deserves to be\nquashed.\nIt is prayed that the addition ... about the issue\nand at the same time observing that A.O. erred in\nallowing the benefit of accumulation under\nprovisions of section 11(3)(c) of the Act. The order\npassed by Ld. Commissioner of Income tax\n(Exemption) is thus bad in the eyes

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

ITA 338/CHANDI/2023[2017-2018]Status: DisposedITAT Chandigarh10 Dec 2025AY 2017-2018

For Appellant: Sh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 263

allowing appropriate relief in\nregard to the addition of the sum of\nRs.1,58,34,30,328 made under section 11(3)(c). The\norder has been passed without considering the facts\nof the appellant and is illegal and deserves to be\nquashed.\n\nIt is prayed that the addition ... about the issue\nand at the same time observing that A.O. erred in\nallowing the benefit of accumulation under\nprovisions of section 11(3)(c) of the Act. The order\npassed by Ld. Commissioner of Income tax\n(Exemption) is thus bad in the eyes

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. CIT(EXEMPTION), CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

ITA 63/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh10 Dec 2025AY 2015-16

For Appellant: \nSh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 263

FOUNDATION FOR UNIVERSAL RESPONSIBILITY OF HIS HOLINESS THE DALAI LAMA,DELHI vs. ITO, EXEMP. WARD-1(1), DELHI

In the result, appeal of the Assessee is allowed

ITA 1798/DEL/2025[2023-24]Status: DisposedITAT Delhi12 Nov 2025AY 2023-24

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.1798/Del/2025 िनधा"रणवष"/Assessment Year:2023-24 बनाम Foundation For Universal Income Tax Officer Responsibility Of His Holiness The Vs. (Exemption), Dalai Lama, Ward 1(1), Core-4A, Ugf, India, New Delhi. Habitat Centre, Upper Ground Floor, Lodhi Road, New Delhi. Pan No.Aaatf0174E अपीलाथ" Appellant ""यथ"/Respondent

Section 11(2)Section 11(3)(c)Section 115BSection 12ASection 143(1)

Mumbai Bench of the Tribunal in the case of Dadar Digamber Jain Mumukshu Mandal (supra), wherein the Tribunal held that the amendment to section 11(3)(c) by Finance Act, 2022 w.e.f. 01.04.2023 which omitted extra period of 1 years following expiry of initial period of accumulation of 5 years ... years period expires in AY 2013-14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) of the Act, the sum accumulated and which remains unspent for charitable purposes, shall be deemed to be income of the person

SHRI CHINTAMANI PARSHWANATH SHWETAMBAR MURTIPUJAK JAIN SANGH,MUMBAI vs. EXEM. WARD 2(3), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

ITA 5038/MUM/2025[2023-24]Status: DisposedITAT Mumbai31 Oct 2025AY 2023-24

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri J. Kala, CAFor Respondent: Shri Virbhadra Mahajan, Sr. DR

Section 11Section 11(2)Section 11(2)(a)Section 11(3)Section 115BSection 12ASection 143(1)

from 01.04.2023 i.e., Assessment Year 2023-24. There were two amendments in Finance Act, 2022 which restricted the utilization up to 5 years. Section 11(3)(c) specifically allowed one more year. 5 Shri Chintamani Parshwanath Shwetambar Murtipujak Jain Sangh AY 2023-24 The words “or in the year immediately ... following the expiry thereof” were deleted. Thus, section 11(3)(c) along with the text at the end of the section allowed the utilization of the accumulated funds for 6 years before the amendment. According to the assessee, this is a prospective amendment made with regard to use of accumulated

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

ITA 337/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh10 Oct 2025AY 2016-17

For Appellant: \nSh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 263

SHRI TALDHWAJA JAIN SWETAMBER TIRTH COMMITTEE,BHAVNAGAR vs. THE ITO (EXEMPTION), BHAVNAGAR

In the result, the appeal of the assessee is allowed

ITA 1240/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad24 Sept 2025AY 2023-24

Bench: DR. BRR KUMAR (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

Section 11Section 11(2)Section 11(3)Section 115BSection 12ASection 143(1)Section 143(1)(a)Section 234A

Mumbai - Trib.), the ITAT held that I.T.A No. 1240/Ahd/2025 A.Y. 2023-24 5 Shri Taldhwaja Jain Swetamber Tirth Committee vs. ITO amendment to section 11(3)(c) by Finance Act, 2022 with effect from 1-4-2023 which omitted extra period of one year following expiry of initial period

THE BOMBAY SOCIETY OF THE FRANCISCAN CLARIST SISTERS OF THE MOST BLESSED SACRAMENT,MUMBAI vs. ITO EXEM WARD 2(4), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2501/MUM/2025[2023-24]Status: DisposedITAT Mumbai22 Sept 2025AY 2023-24

Bench: Shri Pawan Singh & Smt. Renu Jauhriआयकर अपील सुं./Ita No.2501/Mum/2025 (धििाारण वर्ा / Assessment Year: 2023-2024) The Bombay Society Of V/S. Income Tax Officer, The Franciscan Clarist बिाम Ward 2(4), Mumbai Sisters Of The Most 6Th Floor, Mtnl Tel. Ex. Blessed Sacrament Building, Cumballa Hills, St. Anthony’S Home For The Pedder Road, Mumbai Aged, 51, Chapel Road, 400026 Bandra (West), Mumbai 400050 स्थायी लेखा सुं./जीआइआर सुं./Pan/Gir No: Aaatt0738Q Appellant/अपीलाथी .. Respondent/प्रधिवादी धििााररिी की ओर से /Assessee By: Shri Prashant Ghumare, Adv. राजस्व की ओर से /Revenue By: Shri Bhagirath Ramawat, Sr. Dr (Virtually Present) स िवाई की िारीख / Date Of Hearing 03.09.2025 घोर्णा की िारीख/Date Of Pronouncement 22.09.2025 आदेश / O R D E R Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The Addl/Jcit (A)-2 Delhi, [Cit(A)] Dated 28.02.2025 Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For Assessment Year 2023-2024. 2. The Assessee Has Raised The Following Grounds In This Appeal.

For Appellant: Shri Prashant Ghumare, AdvFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 11Section 11(2)Section 115BSection 12ASection 143Section 143(1)Section 143(1)(a)Section 250

years period expires in AY 2013-14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) of the Act, the sum accumulated and which remains unspent for charitable purposes, shall be deemed to be income of the person ... This appeal relates to AY 2013-14 in which the AO sought to apply the provisions of section 11(3)(c). The Assessee did not raise such a plea regarding the applicability of the aforesaid provisions in AY 2014-15 only. 6. There is a reference to section 11(3

SARANGPUR TALIAS POLE PUNCH TRUST,AHMEDABAD vs. THE ITO, WARD-2, EXEMPTION, AHMEDABAD

In the result, the appeal filed by the assessee is allowed

ITA 929/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad16 Sept 2025AY 2023-24

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divetia & Shri Samir Vora, ARsFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR

Section 11Section 11(1)Section 11(1)(c)Section 11(2)Section 11(3)Section 115BSection 119(2)(b)Section 143(1)

lakhs pertaining to financial years 2016-17 and 2017-18 respectively. The Assessing Officer noted that as per amended provisions of section 11(3)(c) of the Act, accumulation period was limited to five years and, thus, he brought said amount to tax as income of assessee. The ITAT held ... that amendment to section 11(3)(c) by Finance Act, Sarangpur Talia’s Pole Punch Trust vs. ITO(E) Asst.Year –2023-24 - 6– 2022 with effect from 1-4-2023 which omitted extra period of one year following expiry of initial period of accumulation of five years is prospective

MESHRI MAHAJAN VANDA,BHAVNAGAR vs. THE ITO (EXEMP), BHAVNAGAR

In the result, the appeal filed by the assessee is allowed

ITA 1261/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2023-24

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul Thakkar, ARFor Respondent: Shri Prateek Sharma, Sr. DR

Section 11(2)Section 11(3)Section 11(3)(iii)Section 115B

lakhs pertaining to financial years 2016-17 and 2017-18 respectively. The Assessing Officer noted that as per amended provisions of section 11(3)(c) of the Act, accumulation period was limited to five years and, thus, he brought said amount to tax as income of assessee. The ITAT held ... that amendment to section 11(3)(c) by Finance Act, 2022 with effect from 1-4-2023 which omitted extra period of one year following expiry of initial period of accumulation of five years is prospective in nature and, thus, same would be applicable only to fresh accumulations from assessment

SHREE MAHAVIR SWETAMBER MURTIPUJAK TAPAGACHHA JAIN GYAN MANDIR TRUST ,MUMBAI vs. ITO WARD 2(3), MUMBAI

ITA 2507/MUM/2025[2023-24]Status: DisposedITAT Mumbai29 Aug 2025AY 2023-24

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Shree Mahavir Swetamber Ao Exemption Ward Murtipujak Tapagachha Jain 2(3), Mtnl Building Mandir Trust Vs. Peddar Road 328, Katrak Road, Wadala W Mumbai-400 026. Mumbai-400 031. Pan : Aaets3498N Appellant Respondent

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri Ashok Sharma

Section 11Section 11(3)(c)Section 115BSection 143(1)

11 are applicable retrospective or prospective in nature. The Ld. AO made an addition of Rs. 59,02,718/- as deemed income under section 11(3)(c) of the Act and levied tax under section 115BBI of the Act. The Ld. CIT(A) has confirmed the addition. 2. The contention ... appellant is that the accumulated income can be utilized in 6th year also under section 11(3)(c) and hence the provisions of amendment relating to A.Y. 2023-24 are not applicable to the Trust. The appellant’s contention is that, since the amendment was not with retrospective effect

ROMAN CATHOLIC CHURCH OF ST. PAUL,MUMBAI vs. ITO EXEM.WARD 2(2), MUMBAI

In the result, the appeal by the assessee is treated as allowed for statistical purposes

ITA 3396/MUM/2025[2023-24]Status: DisposedITAT Mumbai28 Aug 2025AY 2023-24

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2023-24 Roman Catholic Church Of St. Income Tax Officer (Exem.), Paul Ward 2(2) St Paul Church, Vs. Dr. Ambedkar Road, Dadar, Mumbai - 400014 (Pan : Aaatr2742L) (Appellant) (Respondent)

For Appellant: Shri Haridas Bhat, CAFor Respondent: Shri Annavaram Kosuri, CIT DR

Section 10Section 11Section 11(2)Section 11(2)(a)Section 115BSection 12ASection 143Section 143(1)Section 143(3)

from 01.04.2023 i.e., Assessment Year 2023-24. There were two amendments in Finance Act, 2022 which restricted the utilization up to 5 years. Section 11(3)(c) specifically allowed one more year. The words “or in the year immediately following the expiry thereof” were deleted. Thus, section 11(3)(c ... years period expires in AY 2013-14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) of the Act, the sum accumulated and which remains unspent for charitable purposes, shall be deemed to be income of the person

ST. ANTHONYS CHURCH,MUMBAI vs. ITO WARD 2(3), MUMBAI

In the result, appeal of the assessee is allowed

ITA 3011/MUM/2025[2023-24]Status: DisposedITAT Mumbai28 Aug 2025AY 2023-24

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2023-24 St. Anthony’S Church Ito Exem, Ward 2(3), Mumbai St. Anthony’S Church, Marve Road, Malwani, Vs. Malad, Mumbai – 400094. (Pan: Aacts6737L) (Appellant) (Respondent) Present For:

For Appellant: Shri Haridas Bhat, CAFor Respondent: Shri Aditya M. Rai, Sr. DR

Section 10Section 11Section 11(2)Section 11(2)(a)Section 11(3)Section 115Section 115BSection 12ASection 143Section 143(1)

from 01.04.2023 i.e., Assessment Year 2023-24. There were two amendments in Finance Act, 2022 which restricted the utilization up to 5 years. Section 11(3)(c) specifically allowed one more year. The words “or in the year immediately following the expiry thereof” were deleted. 6 St. Anthony’s Church ... Thus, section 11(3)(c) along with the text at the end of the section allowed the utilization of the accumulated funds for 6 years before the amendment. According to the assessee, this is a prospective amendment made with regard to use of accumulated funds and thus, making the additions

SHRI VASUPUJYA SWAMI MAHARAJ TEMPLE TRUST,PUNE vs. ITO (EXEMPTION) WARD 1(2), PUNE

In the result, the appeal filed by the assessee is allowed

ITA 1288/PUN/2025[2023-24]Status: DisposedITAT Pune22 Jul 2025AY 2023-24

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Date of hearing

Section 11Section 11(2)Section 11(3)Section 12ASection 143(1)Section 143(1)(a)Section 250

years period expires in AY 2013- 14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) of the Act, the sum accumulated and which remains unspent for charitable purposes, shall be deemed to be income of the person ... This appeal relates to AY 2013-14 in which the AO sought to apply the provisions of section 11(3)(c). The Assessee did not raise such a plea regarding the applicability of the aforesaid provisions in AY 2014-15 only. 6. There is a reference to section 11(3

SHRI ISHWARLAL GULABCHAND VARDHAMANTAP AYAMBIL TRUST,PUNE vs. ITO WARD 7(1), PUNE

In the result, the appeal filed by the assessee is allowed

ITA 1287/PUN/2025[2023-24]Status: DisposedITAT Pune22 Jul 2025AY 2023-24

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Date of hearing

Section 11Section 11(2)Section 11(3)Section 12ASection 143(1)Section 143(1)(a)Section 250

years period expires in AY 2013- 14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) of the Act, the sum accumulated and which remains unspent for charitable purposes, shall be deemed to be income of the person ... This appeal relates to AY 2013-14 in which the AO sought to apply the provisions of section 11(3)(c). The Assessee did not raise such a plea regarding the applicability of the aforesaid provisions in AY 2014-15 only. 6. There is a reference to section 11(3

GMDC SCIENCE & RESEARCH CENTRE,,AHMEDABAD vs. THE INCOME TAX OFFICER (EXEMPTION),, PALANPUR

In the result, the appeal filed by the assessee is Allowed for Statistical purpose

ITA 958/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad18 Jul 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri T.R. Senthil Kumar

For Appellant: Shri Manish J. Shah, Shri Jimi Patel &For Respondent: Shri Ankit Jain, Sr. DR

Section 11(2)Section 11(3)Section 12ASection 143Section 143(2)Section 147Section 148

charge was not created for non-utilisation of the amount within the period specified in Section 11(2) or further period provided in Section 11(3)(c) of the Act. On closer scrutiny of the provision as it ITA Nos.957&958/Ahd/2015 A.Ys. 2008-09 & 2011-12 6 stands ... other words, no charging provision was created to tax the accumulation which was found to be in violation as per provision contained in Section 11(3)(c) of the Act. It is apposite to note that to overcome this aforesaid glaring lacuna by bringing amendment in Finance

GMDC SCIENCE & RESEARCH CENTRE,,AHMEDABAD vs. THE INCOME TAX OFFICER (EXEMPTION),, PALANPUR

In the result, the appeal filed by the assessee is Allowed for Statistical purpose

ITA 957/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad18 Jul 2025AY 2008-09

Bench: Dr. Brr Kumar & Shri T.R. Senthil Kumar

For Appellant: Shri Manish J. Shah, Shri Jimi Patel &For Respondent: Shri Ankit Jain, Sr. DR

Section 11(2)Section 11(3)Section 12ASection 143Section 143(2)Section 147Section 148

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