Recently, an amendment was brought in through the Finance Act 2023 in section 11 of the Income Tax Act, 1961, through which only 85% of the total sums paid or credited by one charitable entity to another charitable entity will be deemed to be “application” towards charitable purposes. This amendment was brought in to discourage the practice of forming multiple layers of charitable entities in order to retain more than 15% at each stage. However, it may seriously impact those charitable entities which are working on channelizing the donations by aggregating donations from multiple donors and applying almost whole of the donations by contributing to charitable entities engaged in actual application towards end causes. Thus, these charitable entities that act as aggregators can be subject to taxation at maximum marginal rates in spite of applying almost 100% of the donations received by it by way of donations to other charitable entities. This deeming provision causes uncertainty for the charitable entities, and a clarification from CBDT in this respect would be welcome.