Section 117 Amendment Not Retrospective: ITAT Allows Tata Social Welfare Trust’s Pre-Amendment Exemptions u/s 10(34), 10(35)

The Income Tax Appellate Tribunal (ITAT) ruled that the amendment to Section 117 of the Income Tax Act is not retrospective, upholding Tata Social Welfare Trust’s claim for dividend income exemptions under Sections 10(34) and 10(35) for pre-amendment years. The tribunal held that legislative changes impacting exemptions must apply prospectively unless explicitly stated otherwise. The decision reaffirms judicial protection for taxpayers against retrospective taxation and underscores interpretational clarity in exemption provisions. It also highlights the importance of consistent application of tax law principles and fair treatment of charitable trusts in pre-amendment contexts.