1989 (8) TMI 19

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....aw to this court: "Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the assessee's right to accumulate 25% of the total income of the previous year extended to the deemed income under section 11(3) of the Income-tax Act, 1961, added therein in the circumstances mentioned above ?" The facts found by the Tribunal as stated in the statement....

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....ion of the Appellate Assistant Commissioner observed: The legal fiction contained in section 11(3) of the Income-tax Act, 1961, should be allowed to play to the fullest extent and there is no warrant to take a restricted view for denying the exemption which is specifically allowed by the statute. In fact, as per the law as stood from April 1, 1976, charitable trusts are permitted to accumulate up....