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2018 (11) TMI 946 - AT - Income TaxExemption u/s 11 - Allowability of set off of excess expenditure of earlier years amounts to application for the purpose of section 11 - Held that:- The assessee is a trust for religious purposes & involved in the activity of running hospitals and several charitable activities. The assessee’s trust has been applying more income towards its object then its income earning for the last several years. It is also noticed that the ld.CIT(A) has placed reliance on the judgment of various High Courts to held that there is nothing in section 11(1)(a) of the Act, which shall indicate that the expenditure incurred in the earlier years cannot be met out of the income of the subsequent years can be carry forward. We have noticed judgment of various High Courts including jurisdictional High Court wherein the identical issue has been decided in favour of the assessee. the assessee trust is entitled to set off of excess expenditure of earlier years in subsequent assessment years as application of income. - Decided against revenue
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