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TMI Blog2021 (9) TMI 179X X X X Extracts X X X X X X X X Extracts X X X X ..... e AO that the amount could have been accumulated only for some specific purpose and not for the general purposes does not hold good. Before us, no fallacy in the findings of CIT(A) has been pointed out by the Revenue nor has the Revenue placed on record any contrary binding decision in its support. In view of the aforesaid facts, we find no reason to interfere to the order of CIT(A) and thus the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ter assessment was framed u/s. 143(3) of the Act vide order dated 05.12.2016 and the total income was determined at ₹ 2,04,45,515/-. Aggrieved by the order of AO, assessee carried the matter before the CIT(A) who vide order dated 31.10.2017 (Appeal No. 382/2016-17) allowed the appeal of the assessee. Aggrieved by the order of CIT(A), Revenue is now in appeal before us and has raised the foll ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unspent accumulated surplus that was carried forward from A.Y. 2008-09. AO was of the view that as per the provision of Section 11(2) of the Act, the accumulation has to be for specific purpose which may be allowed to change u/s. 11(3) of the Act considering the circumstances of the case. He was of the view that claim of the assessee to utilize unutilized accumulation for general purpose was not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6. Learned AR on the other hand reiterated the submissions made before the CIT(A) and supported the order of CIT(A). 7. We have heard the rival submissions and perused the materials available on record. We find that CIT(A) while relying on the various decisions cited in the order has held that the contention of the AO that the amount could have been accumulated only for some specific purpose ..... X X X X Extracts X X X X X X X X Extracts X X X X
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