Section 11: Renovation Expenditure on School Building Allowable as Application of Income, Ownership Not a Prerequisite

Bombay Society of the Salesian Sisters India Vs ITO (ITAT Mumbai) The case involves the Bombay Society of the Salesian Sisters India, a registered society and public trust, which incurred expenditure on repairing a school building owned by another charitable trust. The Assessing Officer (AO) disallowed the expenditure under Section 11(1)(a) of the Income Tax Act, asserting that the building did not belong to the appellant society. Appeal and CIT(A)’s Order: The appellant appealed to the Commissioner of Income Tax (Appeals) [CIT(A)], who, despite the appellant’s alleged non-respons...