2006 (3) TMI 126

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....e and granting registration to it in terms of section 11(2) of the Income-tax Act, 1961, clearly recorded a finding that the accumulated amount had been spent by the assessee for purchase of land for setting up a school. The Tribunal has, in this connection, referred to the payment of earnest money of Rs. 1 lakh by a bank draft on March 27, 1997, and the purchase of the property in May 1997, in te....

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....e Assessing Officer was not justified. He overlooked that in both the quantum of income sought to be accumulated was the same. The assessee has in fact finalised the purchase of the land in March 1997, itself and as shown by the clarificatory resolution an earnest money of Rs. 1 lakh was paid by demand draft on March 27, 1997, itself which is within the relevant accounting year. The land was actua....