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Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in law in confirming the order of the Commissioner of Income-tax (Appeals) in allowing set-off of excess/ expenditure/application pertaining to current assessment year and earlier years against the income of the future assessment year by fol­lowing its earlier orders?

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Sec. 11 of Income Tax Act, 1961—Trust - Charitable Purpose— Income derived from the trust property has also got to be com­puted on commercial principles and if commercial principles are applied, then adjustment of expenses incurred by the trust for chari­table and religious purposes in the earlier years against the income earned by the trust in the subsequent year will have to be regarded as application of income of the trust for charitable and religious pur­poses in the subsequent year in which adjustment had been made having regard to the benevolent provisions contained in section 11 of the Act and such adjustment will have to be excluded from the income of the trust under section 11(1)(a) - PR. CIT V/s GREEN WOOD HIGH SCHOOL - [2020] 426 ITR 364 (KARN)

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