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    <title>2025 (12) TMI 1098 - ITAT DELHI</title>
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    <description>The dominant issue was whether income accumulated under s.11(2) pursuant to Form No.10 for construction at two specified educational units could be treated as valid application when expenditure was also claimed for other units without seeking the AO&#039;s permission to vary the purpose of accumulation. ITAT held that the assessee&#039;s sole object was running educational institutions, a charitable purpose, and that capital and revenue outgo across all units constituted application of income for charitable purposes; consequently, the benefit of s.11(2) was allowable. However, where the AO found mismatch between claimed capital spend and additions reflected in fixed asset records, ITAT directed allowance of the claim subject to AO&#039;s verification of actual incurrence.</description>
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      <title>2025 (12) TMI 1098 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783558</link>
      <description>The dominant issue was whether income accumulated under s.11(2) pursuant to Form No.10 for construction at two specified educational units could be treated as valid application when expenditure was also claimed for other units without seeking the AO&#039;s permission to vary the purpose of accumulation. ITAT held that the assessee&#039;s sole object was running educational institutions, a charitable purpose, and that capital and revenue outgo across all units constituted application of income for charitable purposes; consequently, the benefit of s.11(2) was allowable. However, where the AO found mismatch between claimed capital spend and additions reflected in fixed asset records, ITAT directed allowance of the claim subject to AO&#039;s verification of actual incurrence.</description>
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