INTRODUCTION :

The Finance Bill, 2021 has proposed to make several amendments (w.e.f. 01 April, 2022 i.e., AY 2022-23) in the provisions, under the Income Tax Act (Act), relating to the taxation of Charitable/ Religious Trusts, Societies, Institutions etc. (Now referred as ‘trusts etc.’). These amendments are proposed in Section 11 of the Act.

In this article, an attempt has been made to understand the nature and impact of these amendments. These amendments have been discussed in the succeeding paras.

Separate Specific Deposit / Investment of Corpus Donations :

From point of view of the Income Tax, the income of the trusts etc. can be classified in to two types i.e.,  (i) voluntary contributions towards corpus fund (popularly known as corpus donations and (ii) Other income (i.e., non corpus income). The income from investment / deposit of corpus donations also falls within second category for purpose of taxation.

The trust etc. are required to apply at least 85% of their non corpus income, towards charitable etc. objects of the trusts (both revenue and capital expenditure are allowed). They can accumulate only up to 15% of the non corpus income. On spending of at least 85% of non corpus income, the remaining accumulated non corpus income becomes exempt u/s. 11(1)(a) / 11(1)(b). The shortfall, if any, in 85% expenditure (or accumulation over 15%) is included in taxable income (there are provisions of deemed application but not relevant for present topic). This accumulated income / fund is to be deposited / invested only in the modes specified in the section 11(5) of the Act (i.e., deposits with scheduled banks, post office saving banks, specific immovable properties etc.).

From plain reading of section 11(1) and 11(2), it is very much clear that for deduction of 85% from non corpus income, the non corpus income itself is to be applied. The source of application of income must be the non corpus income of the current year itself.  The application / expenditure out of accumulated non corpus income of earlier years or out of corpus donations of current or earlier years or out of any borrowed funds are not considerable in mandatory 85% application of non corpus income.  But presently there are no provisions in the Act which specifically denies that the application / expenditure out of borrowed funds / corpus funds etc. are not considerable towards application of non corpus income. However, the assessing officer can disallow such application on the basis of section 11(1)(a) and (b) themselves.

There is an another issue i.e., there are many judicial decisions (as well as a CBDT circular) which says that such disallowed application out of borrowed funds may be considered as application of non corpus income in the subsequent year /(s), when the borrowed funds will be repaid out of the non corpus income of that subsequent year /(s). But regarding subsequent allowance of disallowed application / expenditure out of corpus donations or out of accumulated 15% non corpus income of earlier years, there are no specific provisions in the present Act. There may also not be any judicial decision in this regard.

There is one more related issue that if in any year, more than 85% of non corpus income is spend, and in any subsequent year less than 85% of non corpus income is spend, then whether the set off of the excess expenditure in the earlier year can be allowed in shortfall of 85% expenditure in subsequent years. There are some judicial decisions, which says that excess expenditure of earlier years can be allowed in subsequent years when there is shortfall in 85% expenditure. According to them the 85% application of income should not be seen on year to year basis but should be seen on overall basis. For example if a trust having age of 2 years has non corpus income of Rs. 200000/- in one year and Rs. 300000/- in second year (i.e., total Rs. 500000/- in whole life) then  at least 85% of income of whole age should have been applied i.e., Rs. 4,25,000/- should have been applied irrespective of the year of application i.e., it may be possible that in the first year whole Rs. 200000/- is applied and in the second year only Rs. 2,25,000/- (less than 85% of Rs. 300000/- i.e., Rs. 255000/-) is applied.

 As against non corpus income, the corpus donations are fully exempt u/s. 11(1)(d), without any requirement of applying them towards objects. They can be fully accumulated without any tax impact. However, there is no specific bar on voluntary spending thereof (often in case of need, the trusts etc. spends out of corpus donations). The accumulated corpus donation / fund is also required to be deposited / invested only in the modes specified in the section 11(5) of the Act, as mentioned above.

Under the present law, there is no requirement to invest / deposit corpus and non corpus income / fund separately. They can be invested jointly without any bifurcation. Now, it is proposed in the Finance Bill, that deposit / investment of corpus donations should be specific (i.e., separate from non corpus income).

For example, suppose the non corpus income is Rs. 5,00,000/-, corpus donation is Rs. 2,00,000/-. Here at least 85% of Rs. 5,00,000/- i.e., Rs. 4,25,000/- is required to be applied. Thus, an amount up to Rs. 75,000/- can be accumulated. If Rs. 4,25,000/- or more is applied then remaining amount out of Rs.5,00,000/- will not be part of taxable income. However, if there is any shortfall, say only Rs. 1,00,000/- is applied then shortfall of Rs. 3,25,000/- will be part of taxable income. The basic exemption limit is Rs. 2,50,000/-, after allowing the same, the trust will be required to pay tax on remaining Rs. 75,000/- on slab rate basis.

Here no part of corpus donation of Rs. 2,00,000/- is mandatorily required to be spent for getting exemption. The accumulated corpus donation i.e., Rs. 200000/- and   accumulated non corpus income Rs. 75,000/- (no shortfall case) or Rs. 4,00,000/- (shortfall case)  are to be deposited separately (under new provisions) in modes specified u/s. 11(5). Under the present provisions they can be deposited / invested jointly without any specification.

IMPORTANT ISSUES AND PROBABLE PROBLEMS :

(1) Here it is important to note that the separate specific investment of corpus income is not merely directory but has been added as the basic condition for exemption of corpus contributions u/s. 11(1)(d). If the same is not properly complied with then, the exemption u/s. 11(1)(d) may not be available in respect of such corpus contributions.

 (2) The separate specific investment / deposit is to be made only in respect of corpus donations. Nothing has been said in the Finance Bill in respect of income which will be earned on investment / deposit of corpus contributions. Under the Act, the corpus donations and income from investment of corpus donations are different. The corpus donations are exempt without requirement of 85% expenditure whereas at least 85% of income from corpus investment is required to be spent for getting exemption. It is not practically possible to keep the corpus donation investment and income there from separate. For example, if corpus donation is kept in a particular saving bank account, then the interest thereon will be credited by the bank in the same saving account. In such case, the mandatory requirement of specific and separate investment of corpus donation may not be exactly and perfectly complied with. This may create litigations. Therefore, position regarding investment income on corpus donations requires to be clarified.

(3) The above separate investment / deposit may have to be made only in respect of income / funds earned / accumulated from financial year 2021-22. The common investments of corpus donations and other funds made prior to that period may not have to be separated.

(4) So far as investment in banks, post office etc. is concerned, separate deposit/ investment of these two different type of income / funds may be made. But when there will be investment in any immovable property (permissible mode u/s. 11(5)), it may not be practically possible to comply with the new provisions. Suppose, if the above accumulation of Rs. 75000/- non corpus and Rs. 200000/- corpus are invested in buying/constructing any building then it may not be possible to separate the one and same building in to two parts (i.e., investment out of corpus donations and investment out of non corpus income).

Application Out Of Corpus Donations Not To Be Considered For 85% Application Required For Non Corpus  Income : It is also proposed (vide proposed Explanation 4 to Section 11(1)) that any application out of corpus donations will not be considered for purpose of mandatory 85% application out of non corpus income.

For example, suppose in the above case, corpus income of Rs. 200000/- is spent and out of non corpus income only Rs.2,25,000/- is spent then the shortfall of Rs. 200000/- in minimum mandatory spending out of non corpus income shall not be compensated with voluntary spending of Rs. 200000/- out of corpus income. For understanding that whether this type of situation can arise in practical life we can consider a hypothetical Income and Expenditure Account and Balance Sheet as under :

Income & Expenditure Account

Expenditure Amount (Rs.) Income Amount (Rs.)
Expenses Towards Objects

Surplus During Year

Rs.2,25,000

Rs. 2,75,000

Non Corpus Income 500000
  Rs. 5,00,000   Rs. 5,00,000

Balance Sheet

Funds And Liabilities Amount (Rs.) Assets Amount (Rs.)
Corpus Fund

 

Income & Expenditure Account

200000

 

 

275000

Immovable Property (Corpus)

 

Bank Deposits (Non Corpus)

2,00,000

 

 

2,75,000

 

4,75,000   4,75,000

In this case, out of above non corpus income of Rs. 5,00,000/- only Rs. 2,25,000/- are spent and Rs.2,75,000/- are deposited in bank and above corpus donations of Rs. 2,00,000/- are invested in immovable property. Presently it is a general practice to claim that mandatory 85% expenditure of Rs. 4,25,000/- has been met as Rs. 225000/- above direct revenue expenditure + capital expenditure Rs. 200000/- (i.e., investment of corpus donation in immovable property).

This situation (though it is in a general practice) is considered as case of double deduction i.e., firstly the amount of Rs. 2,00,000/- has been claimed as exempt u/s. 11(1)(d) and secondly, the same amount has been further claimed as deduction u/s. 11(1) as application of non corpus income. With intension to avoid this situation of double deduction, the new provisions might have been proposed.

(Note : – Practically, the “application of income by way of capital expenditure” and “investment of income in immovable properties” are almost one and same, which may be root cause of many problems in taxation of trusts etc.).

IMPORTANT ISSUES AND PROBLEMS : Generally, the corpus and non corpus funds and their investments, spending etc. remains mixed. It is practically very difficult to make clear cut bifurcation, management and accounting in this regard, particularly when  large no. of trusts are of small and medium size. Their managing peoples are also not much literate. They give their services to the institutions voluntarily without any remuneration etc. Under these circumstances, the proposed provisions may create additional burden and complications.

 Application Out Of Corpus Donations Is Allowable In Subsequent Period, When Deposited Back To Corpus Investment Out Of Non Corpus Income :

It is also proposed (vide proposed Explanation 4 to Section 11(1)) that if the expenditure incurred out of corpus donation is compensated out of non corpus income in any subsequent year (i.e., expenditure out of corpus income is deposited back in corpus investment etc., out of non corpus income) than such deposit back will be treated as application of non corpus income in the year of deposit back.

For example, suppose if there is shortfall of Rs. 200000/- in Assessment Year 2022-23 in minimum mandatory 85% of non corpus income and the same has been met out of corpus income in A.Y. 2022-23 then the benefit of Rs. 200000/- applied out of corpus income will not be available in A.Y. 2022-23 but suppose in later years say in Assessment Year 2023-24, the above amount of Rs. 200000/- is deposited back in corpus investment, out of non corpus income of A.Y. 2023-24, then such deposit back will be counted in minimum mandatory application of non corpus income of A.Y. 2023-24.

The impact of the above amendment is that the expenditure out of corpus donations (even revenue expenditure) is not banned, only its deduction has been deferred till deficit in the corpus investment is reimbursed out of non corpus income. In other words, for practical purposes it can be understood that, the funds can be taken from the corpus fund for 85% or more non corpus spending and later on, on availability of non corpus income the same can be compensated to the corpus fund and then deduction can be taken.

Let us see some practical situations in this regard. In case of capital expenditure out of corpus contribution, as mentioned in the above balance sheet, the expenditure has been made out of corpus income but the same is laying in the specific investment for corpus income itself (that too in mode specified u/s. 11(5)). In this situation nothing is to be deposited back to the corpus investment. Then after disallowance, there will be no situation to reclaim the deduction in any later year.

In respect of revenue expenditure, let us consider an another Income & Expenditure Account of concerned circumstances.

Income & Expenditure Account

Expenditure Amount (Rs.) Income Amount (Rs.)
Expenses Towards Objects

 

Rs.7,00,000 Non Corpus Income

Deficit For Year

500000

200000

  Rs. 7,00,000   Rs. 7,00,000

Here, Rs. 200000/- has been spent out of corpus contribution, in the later period when the above amount (wholly or partly) will be compensated back to specific corpus investment, out of non corpus income, then as per the new provisions it should be treated as application of non corpus income of year of compensation (to the extent of amount of compensation). But in such type of cases also, there is a difficulty in claiming deduction in later years. Because the proposed amendment has also provided (vide proposed Explanation 5 to Section 11(1)) that set off or deduction of excess application of earlier year shall not be allowed in computing the application of non corpus income in later years. Here the required expenditure was only Rs. 4,25,000/-. The same was made out of non corpus income itself. The expenditure made out of corpus donations was in excess of minimum mandatory requirement of 85% hence the same may not be allowable despite deposit back in the corpus investment in the later years, out of non corpus income.

Let us consider one more example for revenue expenditure.

Income & Expenditure Account

Expenditure Amount (Rs.) Income Amount (Rs.)
Expenses Towards Objects

Surplus During Year

Rs.4,25,000

Rs. 75,000

Non Corpus Income 500000
  Rs. 5,00,000   Rs. 5,00,000

Balance Sheet

Funds And Liabilities Amount (Rs.) Assets Amount (Rs.)
Corpus Fund

Income & Expenditure Account

200000

75000

Bank Deposits (Non Corpus) 2,75,000
2,75,000   2,75,000

 In this type of cases, the legal position for claiming deduction in later years is appearing. But if we observe the above financial statements, it appears that the new provisions do not have any material result. Here only the name of the deposit “Bank Deposit (corpus)” has become “Bank Deposit  (non corpus)” for Rs. 200000/-. There is no change in the assets position or in liquidity position.

Apart from the above situations, many other situations may arise in real life. In some of the situations, the above provisions may appear to be absurd / unnecessary / without serving any purpose.

This provision may be with good intension to give benefit to the trusts due to which the outgoings out of corpus donations may not get waste and the trust may get deduction for that in later years. But the situation to get the real benefit do not appear in practical scenario.

Application Out Of Borrowed Funds Not To Be Considered For 85% Application Required For Non Corpus  Income : It is also proposed (vide proposed Explanation 4 to Section 11(1)) that any application out of loan or borrowings will not be considered for purpose of mandatory 85% application out of non corpus income. But the same will be allowable in the later years when the loan or borrowings will be repaid out of the non corpus income of that subsequent years.

The above amendment is also in the same line with amendment regarding application out of corpus donations. The main thrust of this amendment is also that all outgoing applications are to be regarded as application, but the year of allowance will be taken only when actually the non corpus income will be used. This provision is very good. For example, if the trust has to purchase a building and it has not sufficient funds with it. In such a situation it can take loan / borrowings and can purchase the building. The purchase of building out of loan funds will not be allowed as capital expenditure in the year of purchase but when the loan will be repaid out of non corpus income (wholly or partly in installments) the deduction shall be allowed to the extent of use of non corpus income in repayment of borrowings. In such case actual capital expenditure will be allowed in the year of actual use of non corpus income.

The above method is already being implemented by the Income Tax Department in return ITR 7. The above amendment is also in line with judicial decisions and CBDT circular. Nothing new is there in this amendment. It is merely for giving further force to existing legal position.

Application Out Of Accumulated 15% Non Corpus Income of Earlier Year Not Addressed :  The accumulated income at 15%  pertaining to earlier years is an already exempt income. Any allowance of deduction regarding application thereof in subsequent years will also amount to double deduction.  The income tax return form for trusts etc. i.e., ITR-7 specifically excludes any expenditure made out of 15% etc. accumulated non corpus income of earlier years, as deduction against minimum mandatory application requirement of 15% in current year. However, like issue of application out of borrowed funds, corpus funds etc. this issue has not been addressed specifically in the present provisions as well as in the proposed provisions under the Act. This has remained to be addressed.

Amount Required To Be Applied Out Of Non Corpus Income Is To Be Computed Ignoring Excess Application In Earlier Years :

It has been mentioned earlier that in many judicial decisions, it has been held that excess expenditure in earlier years should be allowed to be set off against short application in subsequent years. It appears that due to that above prevailing legal position, the amendment (vide Explanation 5 to section 11(1)) has been proposed. In the amendment it has been specifically proposed that in computing the 85% minimum mandatory application, no set off / deduction etc. of excess application of earlier years shall be considered.

GIST OF AMENDMENTS: Thus, it appears that now the system of taxation of trust will be such that (i) corpus contributions will continue to be exempt subject to their specific investment / deposit (no mandatory requirement of 85% expenditure out of corpus contributions (ii) application / spending out of corpus fund can be voluntarily made. Its deduction will not be available against mandatory 85% application on non corpus income. However, if in later years if corpus fund is reimbursed for amount applied, out of non corpus income the deduction will be allowable in the year of reimbursement to the extent of amount reimbursed (considering such reimbursement as actual application of non corpus income). (iii) like temporary spending out of corpus donations, the spending out of borrowed funds will be allowed as deduction when the borrowings will be repaid out of non corpus income. (iv) excess spending in earlier years will not be allowed to be set off against shortfall in 85% expenditure in subsequent years.

SIMILAR AMENDMENTS : Amendments have also been made on the similar line in respect of institutions covered under section 10(23C) of the Act and whose provisions are mostly similar to section 11.

RELEVANT PROVISIONS OF FINANCE BILL :

Amendment of section 11.

6. In section 11 of the Income-tax Act, with effect from the 1st day of April, 2022,––

(a) in sub-section (1),––

(i) in clause (d), for the word “institution”, the words,brackets and figures “institution, subject to the condition that such voluntary contributions are invested or deposited in one or more of the forms or modes specified in sub-section (5) maintained specifically for such corpus” shall be substituted;

(ii) after Explanation 3, the following Explanations shall be inserted, namely:––

“Explanation 4.––For the purposes of determining the  amount of application under clause (a) or clause (b),––

(i) application for charitable or religious purposes from the corpus as referred to in clause (d) of this subsection,shall not be treated as application of income for charitable or religious purposes:

Provided that the amount not so treated as application,or part thereof, shall be treated as application for charitable or religious purposes in the previous year in which the amount, or part thereof, is invested or deposited back, into one or more of the forms or modes specified in sub-section (5) maintained specifically for such corpus, from the income of that year and to the extent of such investment or deposit; and

(ii) application for charitable or religious purposes,from any loan or borrowing, shall not be treated as application of income for charitable or religious purposes:

Provided that the amount not so treated as application,or part thereof, shall be treated as application for charitable or religious purposes in the previous year in which the loan or borrowing, or part thereof, is repaid from the income of that year and to the extent of such repayment.

Explanation 5.––For the purposes of this sub-section,it is hereby clarified that the calculation of income required to be applied or accumulated during the previous  year shall be made without any set off or deduction or allowance of any excess application of any of the year preceding the previous year.”;

(b) in sub-section (2), in the Explanation, after the figures and letters “12AA”, the words, figures and letters “or section 12AB”shall be inserted;

(c) in sub-section (3), in clause (d), after the figures and letters “12AA”, the words, figures and letters “or section 12AB” shall be inserted.

RELEVANT EXTRACTS FROM NOTES ON CLAUSE OF FINANCE BILL :

Clause 6 of the Bill seeks to amend section 11 of the Income-tax Act relating to income from property held for charitable or religious purposes.

Clause (d) of sub-section (1) of the said section provides that voluntary contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall not be included in the total income of the trust or institution.

It is proposed to amend the said clause (d) so as to provide that such voluntary

contributions should be invested or deposited in one or more of the forms or modes specified in sub-section (5) maintained specifically for such corpus.

It is further proposed to insert a new Explanation 4 to sub-section (1) so as to provide that––

(A) application out of the corpus shall not be considered as application for charitable or religious purposes for the purposes of clause (a) and (b) of sub-section (1), provided when it is invested or deposited back, into one or more of the forms or modes specified in subsection (5) maintained specifically for such corpus, from the income of the previous year,such amount shall be allowed as application in the previous year in which it is deposited back to corpus and to the extent it is deposited back.

(B) application from loans and borrowings shall not be considered as application for charitable or religious purposes for the purposes of clause (a) and (b) of sub-section (1),provided when such loan or borrowing is repaid from the income of that previous year, such repayment shall be allowed as application in the previous year in which it is repaid and to he extent it is repaid.

It is also proposed to insert a new Explanation 5 to the said sub-section so as to provide that for the computation of income required to be applied or accumulated during the previous ear, no set off or deduction or allowance of any excess application, of any of the year preceding the previous year, shall be allowed.

Explanation to sub-section (2) provides that if any trust or institution accumulates or set off apart its income then payment or credit out of such accumulation, to exempt entities as rescribed in the Explanation, shall not be treated as application. Clause (d) of sub-section 3) provides that such income, credited or paid to entities prescribed, shall be deemed to be income of the trust or institution.

It is proposed to make a reference of section 12AB in the said Explanation to the said sub-section (2) and clause (d) of sub-section (3), which provides for the procedure of registration.

These amendments will take effect from 1st April, 2022 and will, accordingly, apply in relation to the assessment year 2022-2023 and subsequent assessment years.

RELEVANT EXTRACTS FROM MEMORANDUM EXPLAINING PROVISIONS IN FINANCE BILL :

Rationalisation of the provision of Charitable Trust and Institutions to eliminate

possibility of double deduction while calculating application or accumulation

Exemption to funds, institutions, trusts etc. carrying out religious or charitable activities is provided under clause (23C) of section 10 of the Act and sections 11 and 12 of the Act. Section 12A of the Act, inter alia, provides for procedure to make application for the registration of the trust or institution to claim exemption under section 11 and 12. Section 12AB is the new section which comes into effect from the 1st April, 2021.

Under the existing provisions of the Income-tax Act, 1961, corpus donations received by trusts, institutions, funds etc. are exempt as follows:

a) Explanation to third proviso to clause (23C) of section 10 provides that income of the funds or trust or institution or any university or other educational institution or any hospital or other medical institution, shall not include income in the form of voluntary contributions made with a specific direction that they shall form part of the corpus.

b) Clause (d) of sub-section (1) of Section 11 provides that voluntary contributions made with a specific direction that they shall form part of the corpus of the trust or institution shall not be included in the total income of the trust or institution.

These entities are not allowed to accumulate more than 15% of their income or accumulate for specific purpose up to 5 years, other than corpus donations referred above. Instances have come to the notice where the these entities claim the corpus donations to be exempt and at the same time claim their application as part of the mandatory 85% application from income other than such corpus. This results in a situation where the corpus income has been exempted and its application has been claimed as application against the mandatory 85% application of non-corpus income.

Instances have also come to the notice where these entities take loans or borrowings and make application for charitable or religious purposes out of the proceeds of loans and borrowings. Such loans or borrowings when repaid, are again claimed as application. This results in unintended double deduction.

Both these situations, at times, also result in paper loss which is claimed by the assessee as carry forward resulting in unintended short application (less than 85%) in following years.

To ensure that there is no double counting while calculating application or accumulation, it has been proposed that-

a)Voluntary contributions made with a specific direction that it shall form part of the corpus shall be invested or deposited in one or more of the forms or modes specified in sub-section (5) of section 11 maintained specifically for such corpus.

b) Application out of corpus shall not be considered as application for charitable or religious purposes for the purposes of third proviso of clause (23C) and clauses (a) and (b) of section 11. However, when it is invested or deposited back, into one or more of the forms or modes specified in sub-section (5) of section 11 maintained specifically for such corpus from the income of the previous year, such amount shall be allowed as application in the previous year in which it is deposited back to corpus to the extent of such deposit or investment.

c) Application from loans and borrowings shall not be considered as application for charitable or religious purposes for the purposes of third proviso of clause (23C) and clauses (a) and (b) of section 11. However, when loan or borrowing is repaid from the income of the previous year, such repayment shall be allowed as application in the previous year in which it is repaid to the extent of such repayment.

d) Clarify in both clause (23C) of section 10 and section 11 that for the computation of income required to be applied or accumulated during the previous year, no set off or deduction or allowance of any excess application, of any of the year preceding the previous year, shall be allowed.

These amendments will take effect from 1st April, 2022 and will accordingly apply to the assessment year 2022-23 and subsequent assessment years.

[Clauses 5 and 6]

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