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ITAT held that the appellant satisfied statutory prerequisites for accumulation under section 11(2) and for investment under section 11(5). The assessee had set apart Rs.95,00,000 for charitable purposes, filed Form 10 within time, and held the amount in a scheduled bank on 31.03.2018, subsequently investing in bank FDRs on 07.04.2018 and 09.04.2018. With no misapplication or deviation from trust objects, a brief post-year-end placement in prescribed modes did not warrant denial of exemption. The tribunal construed sections 11(2) and 11(5) harmoniously to promote legislative intent, held the procedural disallowance unjustified, and allowed the appeal.
ITAT held that the appellant satisfied statutory prerequisites for accumulation under section 11(2) and for investment under section 11(5). The assessee had set apart Rs.95,00,000 for charitable purposes, filed Form 10 within time, and held the amount in a scheduled bank on 31.03.2018, subsequently investing in bank FDRs on 07.04.2018 and 09.04.2018. With no misapplication or deviation from trust objects, a brief post-year-end placement in prescribed modes did not warrant denial of exemption. The tribunal construed sections 11(2) and 11(5) harmoniously to promote legislative intent, held the procedural disallowance unjustified, and allowed the appeal.
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