2007 (5) TMI 88

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....ax Act, 1961. 3. The Assessee is a Society registered under Section 12-A of the Act. ? 4. Learned counsel for the Assessee has placed before us the objects of the Society which he says were before the Assessing Officer. The objects are taken on record. 5. On a perusal of the objects of the Society, we find that these include following:- "(i)To develop health resources particularly in respect of children belonging to the vulnerable segments of the population; (ii)To educate the people especially the mothers regarding maintenance and improvement of health and nutrition of Children; (iii) To conduct classes and schools for training in matters of health nutrition and all other allied subjects pertaining to medicine and communi....

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.... of accumulation in view of the judgment of this Court in Commissioner of Income Tax vs. Hotel and Restaurant Association [2003] 261 ITR 190. 9. In that decision, the contention of learned counsel for the Revenue was to the effect that the appellate authorities under the Act had failed to appreciate that in the prescribed form, the Assessee did not indicate the specific purpose for which the income was sought to be accumulated and, therefore, the statutory requirement had not been strictly complied with disentitling the Assessee from relief under Section 11(2) of the Act. This Court rejected the contention and held as follows:- "It is true that specification of certain purpose or purposes is needed for accumulations of the trust's inc....