Accumulation by Trusts @ 15% on Gross Receipts or on Net Income?

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A trust gets exemption under section 11 & 12 read with section 13 of the Income Tax Act. There are many conditions which are required to be satisfied for a trust before it gets exemption from tax. One of the condition given in section 11 is that the charitable trust can not accumulate income for more than 15 % in a year. For this , it is also required to file Form 10 as per rule 17 of the Income Tax Rule. However, the question is whether the 15 % accumulation allowed per year is to be counted from the gross receipt during the year or the net income i.e receipt minus the expense.

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