2016 (1) TMI 123

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....ised the following grounds of appeal : "(1) The orders of the authorities below in so far as they are against the appellant are opposed to law, equity, weight of evidence, probabilities, facts and circumstances of the case. (2) The learned CIT(A) is not justified in upholding, in principle, the action of the learned AO in computing the accumulation of income u/s 11(1)(a) of the Act, at 15% of the net income from property held under trust after deducting revenue expenditure incurred by the appellant as against a sum of Rs. 51,52,825/- claimed by the appellant on the basis of the gross income from property held under trust under the facts and in the circumstances of the appellant's case. (3) For the above and other ....

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....   V. Balance   Nil VI. Accumulation u/s11(1)(a) to the extent of 15% of Net surplus (para IV) limited by actual balance as per amount available in the hands of the trust (para VI) 44,30,789   VII. Amount accumulated u/s 11(2) (Form No.10 filed) 7,22,037   VIII. Balance taxable income   Nil IX. Tax thereon   Nil Tax deducted source   Nil X. Balance payable refundable       4. From the above computation, it is clear that vide column No.6, the learned AO observed that only 15% of net surplus is allowed to be accumulation under the provision of sec. 11(1)(a) of the Income-tax Act. 5. The assessee society be....