Whether accumulation under s.11(2) disclosed in Form 10 for...

Whether accumulation under s.11(2) disclosed in Form 10 for construction at two schools could be treated as valid application when expenditure was also incurred on other schools run by the same charitable trust. The tribunal held that the trust's sole object was imparting education, and capital and revenue outgo on all schools run by it constituted application of income for charitable purposes; hence, the benefit of s.11(2) could not be denied merely because spending was not confined to the two named projects. However, since the AO noted discrepancies between claimed building expenditure and additions reflected in fixed asset records, allowance was made subject to verification, and the AO was directed to grant the claim upon such verification. - ITAT