A statutory obligation has been cast on beneficiary trusts to utilise at least 85 Per Cent. of the income derived from the trust property unless accumulated or set apart for application in subsequent years subject to certain stipulated conditions , without any time limit is benevolent in nature, however it cannot be regarded as an obligation envisaged in law. Followed , Maharshi Karve Stree Shikshan Samstha Karvenagar v. ITO ( 2019) 174 ITD 591 (Pune) (Trib) ( AY.2015-16)
Gnyan Dham Vapi Charitable Trust v. Dy. CIT (2020)82 ITR 14 (SN)(Ahd) (Trib)
S. 11 : Property held for charitable purposes – Application of income – Accumulation of income -Retain or accumulate 15 Per Cent. of income without any time limit and is benevolent in nature however it cannot be regarded as an obligation envisaged in Law. [ S. 11(1)(a) , 11(1)(b ) ]