Carry-forward of excess charitable expenditure under Section 11 was rejected for subsequent-year set-off.

Excess expenditure of a charitable trust or institution incurred in an earlier assessment year cannot be carried forward and set off against income of subsequent years under Section 11 of the Income-tax Act, 1961. The Supreme Court found no merit in the contention that such adjustment was permissible in the manner claimed. The claim for set-off was therefore rejected, and the application was dismissed.

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Issues: Whether excess expenditure incurred by a charitable trust or institution in an earlier assessment year can be set off against income of subsequent years by invoking Section 11 of the Income-tax Act, 1961.

Analysis: The Court heard the question of law raised in the application and found no merit in the contention that such earlier excess expenditure could be adjusted against subsequent years' income under Section 11.

Conclusion: The claim for set-off was rejected and the application was dismissed.

Ratio Decidendi: Excess expenditure of an earlier year cannot be carried forward and set off against income of subsequent years under Section 11 of the Income-tax Act, 1961 in the manner claimed.

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