2009 (12) TMI 50

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.... on appeal against the  order of the Income Tax Appellate Tribunal, Madras 'A' Bench, dated 20.7.2007 passed in I.T.A.No.1464/Mds/2006 in respect of the assessment year 1997-1998 by formulating the following substantial questions of law: "(1). Whether on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the conditions stipulated for availing the benefit of accumulation of income under Section 11(2) are not satisfied? (2). Whether on the facts and in the circumstances of the case, the Tribunal is justified in law in holding that for the purpose of accumulation of the income as provided under Section 11(2) of the Income Tax Act, requires specification of the purposes? 3. Whether on the....

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....s of estates are being taken with the concurrence of the High Court. The appellant filed form 10 specifying the purpose for accumulation and there is no dispute that they are not charitable in nature. Aggrieved by the assessment order, the appellant filed appeal to the Commissioner of Income-tax (Appeals) and reiterated the submissions made before the assessing officer. The Commissioner of Income-tax (Appeals) vide his order dated 2.2.2006 accepted the contentions of the appellant and held that the purpose of accumulation delineated by the appellant does not tantamount to being general and vague and the purposes have an individuality and reversed the order of the assessing officer. Aggrieved by the same, the revenue filed an appeal to the I....