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2003 (3) TMI 92

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..... ects for which the trust was created and not for specific purpose was neither prejudicial nor erroneous to the interests of the Revenue ? - B. Whether section 11(2) of the Act makes it necessary for the assessee to make specific mention of any purpose or purposes to enable it to accumulate the income?" - It is not the case of the Revenue that any of the objects of the assessee-company were not for .....

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..... in holding that the accumulation of income by the assessee under section 11(2) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for all objects for which the trust was created and not for specific purpose was neither prejudicial nor erroneous to the interests of the Revenue? B. Whether section 11(2) of the Act makes it necessary for the assessee to make specific mention of an .....

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..... consideration the amounts so accumulated on the ground that in the statutory form the specific object for which the income was sought to be accumulated was not indicated. He, accordingly, brought the said amount to tax. Aggrieved the assessee preferred an appeal to the Commissioner of Income-tax (Appeals), who, by his order dated April 26, 1995, accepted the claim of the assessee. While holdin .....

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..... g its object. Hence, the present appeal. We have heard Mr. R. D. Jolly, learned senior standing counsel for the Revenue. Mr. Jolly submits that the appellate authorities have failed to appreciate that in the prescribed form the assessee had failed to indicate the specific purpose for which the income was sought to be accumulated and, therefore, the statutory requirement had not been strictly co .....

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