Application of income outside India under charitable exemption rejected as earlier binding precedent controlled the issue.

Expenses incurred outside India for the Global Trade Development Programme were examined as to whether they constituted application of income under Section 11(1)(a) of the Income-tax Act, 1961. The issue was already covered by an earlier binding decision on the same question, and that precedent was followed. On that basis, no substantial question of law arose for consideration, and the issue was decided against the assessee and in favour of the Revenue.

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Issues: Whether the expenses incurred outside India on the Global Trade Development Programme amounted to application of income under Section 11(1)(a) of the Income-tax Act, 1961.

Analysis: The question was held to have been answered against the assessee in the earlier binding decision covering the same issue. In that view, no substantial question of law arose for consideration.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

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