https://www.taxtmi.com/caselaws?id=457052 Donations made from accumulated funds under section 11(2) were held not to constitute application of income under section 11; on the facts, the Tribunal found no meaningful distinction between the labels "contribution" and "donation" and no evidence of how the recipient organisations treated the sums. Because such accumulated amounts, when so utilised, are treated as income under section 11(3), the assessment order allowing them as application of income was considered legally erroneous and prejudicial to the Revenue. The Commissioner's revisionary jurisdiction under section 263 was therefore upheld. en-us Thu, 17 Aug 2023 00:00:00 +0530 Tue, 03 Sep 2024 22:33:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457052 Donations made from accumulated funds under section 11(2) were held not to constitute application of income under section 11; on the facts, the Tribunal found no meaningful distinction between the labels "contribution" and "donation" and no evidence of how the recipient organisations treated the sums. Because such accumulated amounts, when so utilised, are treated as income under section 11(3), the assessment order allowing them as application of income was considered legally erroneous and prejudicial to the Revenue. The Commissioner's revisionary jurisdiction under section 263 was therefore upheld. Case-Laws Income Tax Thu, 17 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457052