https://www.taxtmi.com/caselaws?id=25401 A statutory charge on trust corpus did not, by itself, divert post-death dividend income at source, because the income remained available to the trustee and no actual payment or enforceable diversion was shown. The commentary also states that exemption under section 11(1)(a) depends on actual application of income to charitable purposes in India, and that unspent income does not qualify merely because estate duty may be payable or because one intended institution is outside India. It further notes that the 25% accumulation benefit is available only where income is consciously accumulated for the relevant charitable use in India, and that interest under sections 215 and 217 is appealable only on the limited basis recognised by law. en-us Fri, 10 Apr 1987 00:00:00 +0530 Thu, 28 Jan 2010 13:34:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25401 A statutory charge on trust corpus did not, by itself, divert post-death dividend income at source, because the income remained available to the trustee and no actual payment or enforceable diversion was shown. The commentary also states that exemption under section 11(1)(a) depends on actual application of income to charitable purposes in India, and that unspent income does not qualify merely because estate duty may be payable or because one intended institution is outside India. It further notes that the 25% accumulation benefit is available only where income is consciously accumulated for the relevant charitable use in India, and that interest under sections 215 and 217 is appealable only on the limited basis recognised by law. Case-Laws Income Tax Fri, 10 Apr 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25401