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7.6. The AO established that the trust's funds were not invested or utilized in accordance with Section 11(5) of the Act. Instead, funds were diverted through fraudulent means such as inflating expenses and obtaining unaccounted cash, which were not aligned with the charitable objectives of the trust. These actions contravene the provisions of Section 13(1)(d) of the Act, which mandates that the income and assets of the trust be applied solely for charitable purposes and invested in specified modes.

Parul Arogya Seva Mandal Trust & Parul University (ITA 993/Ahd/2023) Asst. Years :2016-17 & 2017-18 of funds for personal gain, violating the trust's charitable objectives and conditions under Sections 11 and 13 of the Income Tax Act.

• M.R. Corporation vs. ITO (ITA No. 3401/Ahd/2010):

The ITAT Ahmedabad held that extrapolation should be based on concrete evidence for the specific period under consideration, and not merely on assumptions or isolated instances.