In the result, appeal of the Assessee is allowed

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(3)(c) is applicable for the accumulations made from A.Y 2023-24 and not for the earlier years. Nothing has been brought on record as to whether the Revenue has challenged the said decision and thus, the same also supports the case of the assessee. 24. In light of the aforesaid discussion, we find merit in the contentions