2019 (6) TMI 1637

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...."1. The Ld. CIT(A) has erred in the law and on facts in allowing the accumulation of Rs. 4,89,00,000/- u/s.11(2) and accumulation of Rs. 1,28,57,204/- u/s.11(1)(a) of the Act without appreciating the fact that the case of the assessee is clearly falling under the proviso (1) & (2) of section 2(15) of the Act." 3. The fact in brief is that assessing officer has passed order u/s. 143(3) of the act on 25th Nov, 2006 determined the total income of the assessee at Rs. 6,17,57,204/- as against total income of Rs. nil declared by the assessee. The assessee is a trust and its main object is to carry out surveys regarding demand for man power requirement in various vocational skill, trade and on the basis of these surveys work out projection of r....

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....ant parts of the order of ITAT vide ITA No. 3378 & 3379/Ahd/2016 is reproduced as under:- "9. We have heard the rival contentions and perused the materials available on record. In the instant case, the deduction claimed by the assessee u/s ll(l)(a)/ll(2) of the Act was denied by the AO on the ground that the activity of the assessee involves advancement of any other abject of general public utility and its receipts exceeds the mandatory limit as specified under proviso to section 2(15) of the Act. From the preceding discussion, we note that there was no appeal preferred by the Revenue against the order of Ld. CIT(A) pertaining to the A.Y. 2011-12 which implies that the order of Ld. CIT(A) reached to \ its finality. In our ....