https://www.taxtmi.com/caselaws?id=467907 A later restriction on set-off of excess application under Explanation 5 to section 11, effective from 01.04.2021, did not apply to the relevant assessment years, so belated filing of the return did not by itself deny carry-forward set-off of excess expenditure. By contrast, corpus treatment of voluntary contributions depends on proof of a specific donor direction under section 11(1)(d); where the record was unclear on that point, the matter required fresh factual examination and was remitted for reconsideration. en-us Fri, 14 Feb 2025 00:00:00 +0530 Wed, 08 Apr 2026 20:27:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467907 A later restriction on set-off of excess application under Explanation 5 to section 11, effective from 01.04.2021, did not apply to the relevant assessment years, so belated filing of the return did not by itself deny carry-forward set-off of excess expenditure. By contrast, corpus treatment of voluntary contributions depends on proof of a specific donor direction under section 11(1)(d); where the record was unclear on that point, the matter required fresh factual examination and was remitted for reconsideration. Case-Laws Income Tax Fri, 14 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467907