20 October 2014
The payment of a sum by one charitable trust to another for utilisation by the donee trust towards its charitable objects is proper application of income for charitable purpose in the hands of the donor trust ; and the donor trust will not lose exemption under section 11, merely because the donee trust did not spend the donation during the year of receipt itself - CBDT Instruction : No. 1132, dated 5-1-1978 [Extracted from CIT v. Sarladevi Sarabhai Trust (No. 2) [1988] 172 ITR 698 (Guj.) at p. 709].