Shortfall Due to its Excess Spending allowed to C/F in full for Set off against Incomes – Section 11

Gnyan Dham Vapi Charitable Trust Vs DCIT (ITAT Ahmedabad) The issue under consideration is whether where a trust has incurred shortfall due to its excess spending in a particular year, such deficit or shortfall allowed to be c/f in full for set off against the incomes in  subsequent years under s.11(1)(a) and Section 11(1)(b) of the Act? ITAT states that, the assessee has not availed the entitlement of accumulation of 15% of income in the instant case. Needless to say, the statutory postulations towards accumulation of 15% of income for indefinite period is an entitlement or a right of absolu...