The assessee has made donation to NGOs  and claimed as application of income.  Assessing Officer accepted said explanation and completed assessment. Commissioner (E) invoked revisionary proceedings on ground that contribution to deserving NGOs even if working in collaboration with assessee would be donation and would be hit by section 11(2) as the  donations to NGOs out of its accumulated funds, same could not be allowed as application of income for charitable or religious purposes and would be deemed as income of assessee. Tribunal affirmed the order of Revision.  (AY. 2017-18)