2004 (1) TMI 11

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..... g of the manifold objects of the trusts would not suffice. Each purpose of accumulation and the amount set apart therefor must be specified before the benefit u/s 11 could be claimed – Assessee’s request for accumulation has been accepted in the preceding and succeeding assessment years and this is the solitary year in which the claims came to be rejected. Further, the objects for accumulation set .....

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..... ld not suffice. Each purpose of accumulation and the amount set apart therefor must be specified before the benefit under section 11 could be claimed. In the instant case, however, we find that the Tribunal gave great importance to the following factual aspects as indicated in paragraph 34 of its order: "34. A reading of the aforesaid reveals the following: (i) The assessee had been allowed the .....

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..... he Tribunal that the Commissioner of Income-tax (Appeals) has not given importance to the aforesaid factual aspects. In paragraph 31, it is observed as under: "At the outset, we would refer to certain facts which have been stated and reiterated by learned counsel for the assessee and which have not been rebutted by the learned departmental representative. The assessee-trust was founded in 1924, a .....

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