https://www.taxtmi.com/caselaws?id=793757 A charitable trust's excess application of income in earlier years was treated as adjustable against income of a later year on commercial principles, and such adjustment was regarded as application of income in the year of set-off under section 11. The absence of a specific carry-forward claim in the earlier year's return did not, by itself, defeat the claim. Explanation 5 to section 11(1) was treated as prospective and not applicable to AY 2017-18. Because the factual availability and quantification of the adjustment required verification from the trust's books, the matter was restored to the AO for limited examination and consequential allowance if the claim was correct. en-us Fri, 19 Jun 2026 00:00:00 +0530 Tue, 23 Jun 2026 08:08:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793757 A charitable trust's excess application of income in earlier years was treated as adjustable against income of a later year on commercial principles, and such adjustment was regarded as application of income in the year of set-off under section 11. The absence of a specific carry-forward claim in the earlier year's return did not, by itself, defeat the claim. Explanation 5 to section 11(1) was treated as prospective and not applicable to AY 2017-18. Because the factual availability and quantification of the adjustment required verification from the trust's books, the matter was restored to the AO for limited examination and consequential allowance if the claim was correct. Case-Laws Income Tax Fri, 19 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793757