Allowing the appeal of the assessee the Tribunal held that essence of provisions of section 11(1)(a) and 11(2) is that there should firstly be income available at disposal of trust capable of either application or accumulation for later application and income available to a trust in such a scenario could only be its commercial income and such income available could be computed after excluding relevant outgoes and unless taxes paid were not deducted it could not be said that amount of income to that extent was available for application or accumulation.  Accordingly the lower authorities were not justified in jettisoning claim of allowing deduction of tax deducted at source in computation of income available for application or accumulation.  (AY. 2016-17)