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2021 (2) TMI 536 - AT - Income TaxExemption u/s 11 - permissible accumulation of 15% of the total income of the appellant contemplated in section 11(1)(b) - method of computation - whether capital expenditure incurred by the appellant in the purchase of the printing machinery at the cost financed out of Bank loan does not qualify for the claim of application in computing the income of the Appellant Trust? - HELD THAT:- CIT (Appeals) computed the application amount wherein he has mentioned the value of the asset purchased at ₹ 7,15,540. However he has not mentioned how he has arrived the figure. Further we make it clear that purchase of capital asset by availing loan cannot be construed as application of income. There is a difference between application of income and utilization of loan as a source for acquisition of capital asset. Only the repayment of loan out of income will be construed as application of income.
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