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2018 (6) TMI 1833 - ITAT RAJKOTExemption u/s 11 - computing benefit of accumulation - inclusion/exclusion of deemed income - HELD THAT:- A careful perusal of the language employed in section 11 makes it crystal clear that exemption is available only on the ‘income (within the meaning of section 11 and not on the ‘deemed income’). Consequently, the assessee cannot accumulate deemed income either u/s 11(1)(a) or 11(2). As following the esteemed views of Natwarlal Chowdhury Trust case [1989 (8) TMI 19 - CALCUTTA HIGH COURT] we uphold the plea of the assessee that, for the purpose of computing benefit of accumulation, deemed income is to be taken into account. The addition as confirmed by the CIT(A), must, therefore, stand deleted. We order so.
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