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The Tax Publishers2020 TaxPub(DT) 0377 (Kol-Trib) : (2020) 185 ITD 0498 INCOME TAX ACT, 1961
Section 11(1)(a)
Any amount or expenditure which was application of income, could not be considered for determining fifteen per cent to be accumulated. In case of assessee trust and accumulation under section 11(1)(a) had to be allowed as claimed by assessee.
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Charitable trust - Exemption under section 11 - Application of income - Computation of 15% accumulation for application in future---AO computed at 15% of net income, i.e., gross receipts minus revenue expenditure
Assessee was a charitable trust registered under section 12A. Question arose for consideration was whether 15% accumulation for application in future had to be calculated on gross receipt or net receipt after deduction of revenue expenditure. Assessee claimed accumulation of income for application for charitable purpose at 15% of gross receipts.Held: Any amount or expenditure which was application of income, could not be considered for determining fifteen per cent to be accumulated. In case of assessee trust and accumulation under section 11(1)(a) had to be allowed as claimed by assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14 & 2014-15
INCOME TAX ACT, 1961
Section 69C
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