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The first common issue urged by the assessee in AY 2012-13 and 2013- 14 relate to the disallowance of amount utilized for acquisition of assets as application of income u/s11 of the Act. The second common issue urged in all the four years (AY 2012-13 to 2015-16) relate to the disallowance of claim of repayment of loan as application of income u/s 11 of the Act.

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Sec. 11 of Income Tax Act, 1961—Charitable Purpose — Since the assessing officer has disallowed claim of “application of income” in respect of assets purchased out of loan funds and also repayment of loans, the income came to be assessed in positive figure, hence there was no requirement of holding that the deficit shall be carried forward, accordingly, this issue is restored to the file of AO with the direction to allow carry forward of deficit, if any, computed in any of the years — A. SHAMA RAO FOUNDATION Vs. ASSTT. CIT [2020] 78 ITR (TRIB) 374 (ITAT-BANGALORE)

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