TMI Blog1984 (11) TMI 121X X X X Extracts X X X X X X X X Extracts X X X X ..... st which was not utilised during the year when the income accrued and the assessee trust did not make any application to the ITO for accumulation of the same. However, is was recognised by the CIT. Since within immediately next succeeding year, the said amount was spend out, which was found as a fact by the AAC, she accepted the contention of the assessee and reversed the finding of the ITO, grant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the AAC in his order. This is also true that the trust in question is not a creation by the business house. It is really a charitable trust and purpose is also apparent and it is for that purpose that the funds are utilised. There may be a technical flaw that application for accumulation was not there. Had it been given in the next year, it could be a case of condonation but the very fact is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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