TMI Blog2006 (3) TMI 114X X X X Extracts X X X X X X X X Extracts X X X X ..... ourt in CIT v. Hotel and Restaurant Association [2003] 261 ITR 190, held that the accumulation of its income by the respondent-assessee for a plurality of purposes, was permissible. The present appeal assails the correctness of the said order. Ms. Bansal counsel appearing for the Revenue, argued that the accumulation in the present case was for six different objects out of a total of 22 objects ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ational and other institution engaged in promotion of physical health, mental and intellectual health and so develop selflessness, love truth and real brotherhood. (f) To acquire any movable and immovable property or lease, or gift or hire or purchase for any of the purposes of the society including the above objects." She submitted that while the plurality of the objects for purposes of accum ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... racted above. There is no controversy about five of the said objects being charitable in character. The criticism about the sixth object is that it permits acquisition of property whether movable or otherwise for the achievement of other objects for which the trust/society has been established. It was contended by Ms. Bansal that reference to any of the purposes of the society in clause (f) may in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of those purposes would necessarily imply that the property is acquired for one of the charitable purposes stipulated in the memorandum. The apprehension of Ms. Bansal that the accumulation may be used for acquisition of property to be used for a purpose other than those enumerated in the memorandum is, in our opinion, far-fetched. Reference to the purpose of the trust in clause (f) must necessar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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