Expenditure incurred by trust outside India cannot be considered as application of income

Church’s Auxiliary For Social Action Vs ACIT (ITAT Delhi) In the case of India Brand Equity Foundation vs. Assistant Commissioner of Income Tax (E), Trust, Ward-II, New Delhi [(2012) 23 com 323 (Del)] it was held that amount spent outside India for participating in a fare held outside India cannot be treated as application of income of trust for purpose of section 11(1 )(a). The Hon’ble ITAT observed that if the income of the trust can be applied even outside India so long as the charitable purposes are in India, then there is no need for the trust which tends to promote international ...