2006 (3) TMI 114

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....J.- The Income-tax Appellate Tribunal has, relying upon a Division Bench decision of this court 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 ....

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....children. (d) To establish and run libraries for children and adults. (e) To donate to educational 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....

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....ity of purposes also. The respondent-trust had accumulated its income for six different purposes extracted 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 w....

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....hat be so, clause (f) permitting acquisition of movable or immovable property for achievement of one 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 memorandu....