“Section 11(2)”

Section References (mined)Section 11Section 11(2)636 judgments

The decision most relied on for Section 11(2) is Subramanian and Anr. v. Siemens India Ltd. and Anr. (156 ITR 11), cited in 541 judgments on BharatTax.

Leading authorities on Section 11(2)

Subramanian and Anr. v. Siemens India Ltd. and Anr.

156 ITR 11 · 1985 · High Court

541

citing judgments

When there is a conflict between the decisions of non-jurisdictional High Courts, the view that favors the assessee should be preferred.

CIT v. State Bank of Bikaner & Jaipur

43 Taxmann.com 411 · 2014 · High Court

524

citing judgments

Employee contributions to provident fund, ESI, and other welfare funds, if deposited by the due date for furnishing the return of income under Section 139(1), are allowable as a deduction and cannot be disallowed under Section 36(1)(va) read with Section 2(24)(x) or Section 43B, even if deposited after the due date prescribed by the respective welfare Acts.

ACIT v. Ahmedabad Urban Development Authority

143 Taxmann.com 278 · 2022 · Supreme Court

390

citing judgments

If activities for the advancement of general public utility are carried on as a business, income from such activities is not exempt under Section 11, even if the profits are utilized for the main charitable object. The argument that profits from general public utility activities can be ploughed back to charity to maintain exemption is not a good law.

Addl. CIT v. Surat Art Silk Cloth Manufacturers Association

121 ITR 1 · 1980 · Supreme Court

328

citing judgments

A charitable institution, whose predominant object is general public utility, can engage in non-charitable activities yielding incidental profits, provided these profits are deployed to achieve the dominant charitable object. A subsidiary object, if ancillary to the primary charitable purpose, does not negate the institution's charitable character.

Sole Trustee, Loka Shikshana Trust v. CIT

101 ITR 234 · 1975 · Supreme Court

323

citing judgments

This case defines 'education' under Section 2(15) of the Income Tax Act as systematic instruction, schooling, or training given to the young for preparation for the work of life. It clarifies that 'education' in this context has a narrow meaning, not extending to every acquisition of further knowledge.

Escorts Ltd. v. UOI

199 ITR 43 · 1993 · Supreme Court

267

citing judgments

A statute should not be construed to permit double deduction for the same expenditure unless specifically provided by law.

Indian Molasses Co. Pvt. Ltd. v. CIT

37 ITR 66 · 1959 · Supreme Court

206

citing judgments

Expenditure is defined as money paid out or away, which is gone irretrievably. To be deductible under Section 37(1), expenditure must be wholly and exclusively for business, not capital or personal, and not fall under specific provisions of Sections 30 to 36, often justifiable on grounds of commercial expediency.

CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal

211 ITR 293 · 1995 · High Court

204

citing judgments

A charitable trust can carry forward its excess expenditure from previous years and adjust it against the income of subsequent years, which qualifies as an application of income under Section 11. Additionally, voluntary contributions received for a specific purpose are treated as corpus funds and are not taxable.

Judgments citing Section 11(2)

Achariya Shree Vidhya Sagar Dayoday Pashu Seva Kendra Tendukheda Damoh, Vidhya Nagar Tendukheda Damoh vs. Commissioner (Exemption), Bhopal

In the result, both the appeals in ITA Nos

ITA 31/JAB/2024[NA]Status: DisposedITAT Jabalpur30 Sept 2025

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sameer Jain, Sh. Nishant Jain & Dr. H.SFor Respondent: Sh. Shravan Kumar Meena, CIT DR

Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

been cancelled by the ld. CIT (Exemption), the assessee was being assessed as an AOP. Therefore, the surplus which was accumulated under section 11(2) was added back to the income of the assessee because the assessee was not eligible to claim the same in the absence of a valid

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

touchstone of the condition whether 85% of the same has been applied for charitable purposes or not. Referring to the provisions of Section 11(2) of the Act, he submitted that where 85% of the income of the trust is not applied for charitable purpose by the trust then ... income for charitable purpose nor exercised the option in writing for the accumulation of income as per the provisions of Section 11(2) of the Act. Further, the said finding and computation by the Assessing Officer has neither been challenged before the CIT(A) nor has been challenged before

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda

Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

Executive Officer Arulmigu Subramaniya Swamy Temple, Trichy vs. ITO, Exemptions Ward, Trichy

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 2060/CHNY/2025[2015-16]Status: DisposedITAT Chennai26 Sept 2025AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.2060/Chny/2025 िनधा7रण वष7 /Assessment Year: 2015-16

For Appellant: Shri R. Sumedha, Advocate for Ms. G. Vardini Karthik, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT

Section 11(2)

आयकर अपीलीय अिधकरण ‘सी’ "ायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI माननीय "ी मनु कुमार िग

Vishanthi Educational Trust, Chennai vs. ITO, Exemption Ward-4, Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1956/CHNY/2025[2016-17]Status: DisposedITAT Chennai26 Sept 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Ratnesh Nandan Sahayआयकर अपील सं./I.T.A. No.1956/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Vishanthi Educational Trust, Vs. The Income Tax Officer, New No. 32, Old No. 8, Manna Reddy Exemption Ward 4, Street, T. Nagar 600 017. Chennai. [Pan:Aaatv3798A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. N.V. Lakshmi, Advocate ""थ" की ओर से/Respondent By : Ms. Sandhya Rani Kure, Jcit सुनवाई की तारीख/ Date Of Hearing : 17.09.2025 घोषणा की तारीख /Date Of Pronouncement : 26.09.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 25.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2016-17. 2. The Assessee Raised 9 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified Dismissing The Appeal Of The Assessee Without Condoning

For Appellant: Ms. N.V. Lakshmi, AdvocateFor Respondent: Ms. Sandhya Rani Kure, JCIT

Section 11(2)Section 143(3)

during the relevant FY. Since the assessee has not filed Form No. 10 to claim the accumulation as exempt under section 11(2) of the Income Tax Act, 1961 [“Act” in short], the Assessing Officer completed the assessment under section 143(3) of the Act by assessing total income ... denying the claim of exemption under section 11(2) of the Act. 4. The assessee filed an appeal before the ld. CIT(A) with a delay of 35 days in filing the appeal. The assessee also sought for condonation of delay in Form 35. The ld. CIT(A) dismissed

Roshni Homi Daji Bahu Uddeshiya Shiksha Avm Sarvajanik Nyas, Indore vs. CPC, Bengluru

Appeal is allowed for statistical purposes

ITA 142/IND/2025[2023-24]Status: DisposedITAT Indore25 Sept 2025AY 2023-24

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2023-24 Roshni Homi Daji Bahu Cpc, Bengaluru Uddeshiya Shiksha Avm Sarvajanik Nyas, बनाम/ 119, Kanlindi Kunj, Vs. Pipliyahana Square, Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aaetr9004R Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 22.09.2025 Date Of Pronouncement 25.09.2025

Section 11Section 11(1)(a)Section 11(2)Section 12ASection 12A(1)(b)Section 13(10)Section 139Section 139(1)Section 143(1)

आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND

Holy Cross Church, Mumbai vs. ITO Exem.Ward 1(3), Mumbai

ITA 3526/MUM/2025[2023-24]Status: DisposedITAT Mumbai25 Sept 2025AY 2023-24

Bench: Smt.Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Holy Cross Church Ito(Exem)-Ward 1(3) Senapati Bapat Marg 619, 6Th Floor Lower Parel, Mumbai Vs. Cumballa Hill Telephone 400 013. Exchange, Peddar Road Mumbai-400 026. Pan : Aaath2240R Appellant Respondent

For Respondent: Ms. Vasanti Patel & Shri

Section 11(2)Section 11(3)Section 143(1)Section 143(1)(a)

amount applied for specific objects in A.Y. 2023-24. This A.Y. 2023-24 is the 6th year out of accumulation made under section 11(2) for A.Y. 2017-18 under the relevant provisions of the Act for that assessment year. 2. Against the said addition, the appellant filed an appeal

Whole Sale Cloth Merchant Association, Kota vs. Deputy Commissioner of Income Tax Central Circle Kota, Kota

ITA 962/JPR/2024[2015-2016]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-2016

For Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 11Section 11(2)Section 143(3)Section 147Section 40

erred in making addition of Rs.33,50,772/- to the income of the assessee appellant trust while disallowing the benefit of exemption under Section 11(2) and 11(1)(a) of the Act as claimed by the assessee appellant trust. 5. That on the facts and in the circumstances ... erred in making addition of Rs.5,83,469/- to the income of the assessee appellant trust while disallowing the benefit of exemption under Section 11(2) and 11(1)(a) of the Act as claimed by the assessee appellant trust. 5. That on the facts and in the circumstances

Whole Sale Cloth Merchant Association, Kota vs. Deputy Commissioner of Income Tax Central Circle Kota, Kota

In the result, the appeal of the assessee is allowed in ITA No

ITA 961/JPR/2024[2014-2015]Status: DisposedITAT Jaipur24 Sept 2025AY 2014-2015

For Appellant: Shri Siddharth Ranka, Adv

Section 11Section 11(2)Section 143(3)Section 147Section 40

making addition of Rs. 33,50,772/- to the income of the assessee appellant trust while disallowing the benefit of exemption under section 11(2) and 11(1)(a) of the Act as claimed by the assessee appellant trust. 5. That on the facts and in the circumstances ... making addition of Rs. 5,83,469/- to the income of the assessee appellant trust while disallowing the benefit of exemption under section 11(2) and 11(1)(a) of the Act as claimed by the assessee appellant trust. 5. That on the facts and in the circumstances

Shri Taldhwaja Jain Swetamber Tirth Committee, Bhavnagar vs. The ITO (Exemption), Bhavnagar

In the result, the appeal of the assessee is allowed

ITA 1240/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad24 Sept 2025AY 2023-24

Bench: DR. BRR KUMAR (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

Section 11Section 11(2)Section 11(3)Section 115BSection 12ASection 143(1)Section 143(1)(a)Section 234A

Tirth Committee vs. ITO it as taxable income under section 115BBI of the Act. This amount denoted the income that was accumulated under section 11(2) of the Act in Financial Year 2016–17 for a period of five years and was applied during Financial Year ... sole issue involved in the present appeal relates to the taxability of the amount of Rs.30,00,000/- accumulated under section 11(2) of the Act in Financial Year 2016–17 and utilised during Financial Year 2022–23. The Central Processing Centre (CPC) and the CIT(Appeals) held that since

Wellness Charitable Trust, Bengaluru vs. Commissioner of Income Tax, (Exemptions), Bangalore

In the result, the appeal of the assessee is hereby allowed

ITA 366/BANG/2025[2025-26]Status: DisposedITAT Bangalore23 Sept 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Murali Mohan, CIT (DR)

Section 12A

corpus donations and their proceeds are to be accumulated and utilised for specific charitable purposes, and accumulation is permissible under section 11(2) of the Act. The trust has also filed Form 10 for accumulation of funds for the purpose of constructing a building. Hence, the ld. Commissioner’s observation ... building. 11.5 The assessee has placed on record that Form 10 was filed to accumulate funds for constructing a building. Accumulation under section 11(2) of the Act and interim parking in fixed deposits pending application are expressly permitted. It is settled position of law that mere accumulation or conservation

Wellness Charitable Trust, Bangalore vs. Commissioner of Income Tax, (Exemptions), Bangalore

ITA 365/BANG/2025[2025-26]Status: DisposedITAT Bangalore23 Sept 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Murali Mohan, CIT (DR)

Section 12A

All India Spices Exporters Forum, Ernakulam vs. Income Tax Officer, Exemption Ward, Ernakulam

Appeal is allowed, Ground No

ITA 1072/COCH/2024[2014-15]Status: DisposedITAT Cochin22 Sept 2025AY 2014-15

Bench: The Expiry Of Time Allowed U/S 139(1). As Per Section 11(2), As Applicable For Ay 2014-15 There Was No Date Specified As To The Period Within Which The Form Has To Be Filed For Availing Exemption. The Amendment In Section 11(2) That Filing Of Necessary Forms Before The Due Date Of Filing Return As A Pre-Condition To Claim The Exemption Under Section 11(2) Was Substituted By The Finance Act With Effect From 01.04.2016 Which Is Not Applicable For Ay 2014- 15. Hence The Commissioner Of Income Tax (Appeals) Went Wrong In Denying The Exemption.

For Appellant: Shri. G Surendranath Rao, CAFor Respondent: Smt. Leena Lal, Sr. AR

Section 11Section 11(2)Section 11(5)Section 12ASection 139(1)Section 143(1)Section 154Section 250

ground that no evidence is filed as per Income Tax Rule 17 before the expiry of time allowed u/s 139(1). As per Section 11(2), as applicable for AY 2014-15 there was no date specified as to the period within which the form has to be filed ... availing exemption. The amendment in section 11(2) that filing of necessary forms before the due date of filing return as a pre-condition to claim the exemption under section 11(2) was substituted by the Finance Act with effect from 01.04.2016 which is not applicable

Rohilkhand Educational Charitable Trust, Bareilly vs. DCIT, Central Circle, Bareilly

ITA 182/LKW/2024[2018-19]Status: DisposedITAT Lucknow22 Sept 2025AY 2018-19

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. S.H. Usmani, CIT DR

Section 11Section 11(1)Section 11(2)Section 12ASection 13(3)Section 143(3)Section 250Section 80GSection 80G(5)

exempt under section 11(1) of the Act. The ld. AO also disallowed the accumulation of Rs. 22,00,00,000/- under section 11(2) of the Act and furthermore added back the same of Rs.14,96,91,583/- claimed as purchase cost of fixed assets and application of income ... case, the assessee submitted that the ld. AO had not doubted the authenticity of the donations towards corpus, or the accumulation under section 11(2). He had also not doubted the additions to fixed assets, but had only made the disallowance on account of the fact that the registration

Rohilkhand Educational Charitable Trust, Bareilly vs. DCIT, Central Circle, Bareilly

In the result, both appeals of the assessee in ITA No

ITA 181/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 Sept 2025AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.181 & 182/Lkw/2024 A.Ys.2017-18 & 2018-19 Rohilkhand Educational Vs. Dcit, Charitable Trust, Bareilly Central Circle, Bareilly Pan: Aaatr6902J (Appellant) (Respondent) Assesseeby: Sh. Rakesh Garg, Adv Revenue By: Sh. S.H. Usmani, Cit Dr Date Of Hearing: 14.08.2025 Date Of Pronouncement: 22.09.2025 O R D E R Per Bench: [ These Two Appeals Have Been Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-3, Lucknow Dated 19.03.2024 & 22.03.2024, Passed Under Section 250 Of The Income Tax Act, 1961, For The A.Ys. 2017-18 & 2018-19, Dismissing The Appeals Of The Assessee Against Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “(1).That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Not Considering The Fact That In The Alleged Assessment Order, The Columns Of Name Of Assessee, Pan, Asst Year, Date Of Assessment & Section Under Which Passed, Are Blank. (2)That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Treating The Demand As Valid Which Was Not Computed On The Basis Of Orderthat May Not Be Termed To Be An Order Under Section 143(3). (3) That A Demand Of Tax As Computed In The Computation Sheet Is Without Jurisdiction Void-Ab-Inito & Is Liable To Be Annulled. (4) That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Confirming The Addition Of Rs. 736591857/-Comprising  Corpus Donation Aggregating To Rs 7,68,95,000/-, A.Ys. 2017-18 & 2018-19

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. S.H. Usmani, CIT DR

Section 11Section 11(1)Section 11(2)Section 12ASection 13(3)Section 143(3)Section 250Section 80GSection 80G(5)

The Bombay Society of the Franciscan Clarist Sisters of the Most Blessed Sacrament, Mumbai vs. ITO Exem Ward 2(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2501/MUM/2025[2023-24]Status: DisposedITAT Mumbai22 Sept 2025AY 2023-24

Bench: Shri Pawan Singh & Smt. Renu Jauhriआयकर अपील सुं./Ita No.2501/Mum/2025 (धििाारण वर्ा / Assessment Year: 2023-2024) The Bombay Society Of V/S. Income Tax Officer, The Franciscan Clarist बिाम Ward 2(4), Mumbai Sisters Of The Most 6Th Floor, Mtnl Tel. Ex. Blessed Sacrament Building, Cumballa Hills, St. Anthony’S Home For The Pedder Road, Mumbai Aged, 51, Chapel Road, 400026 Bandra (West), Mumbai 400050 स्थायी लेखा सुं./जीआइआर सुं./Pan/Gir No: Aaatt0738Q Appellant/अपीलाथी .. Respondent/प्रधिवादी धििााररिी की ओर से /Assessee By: Shri Prashant Ghumare, Adv. राजस्व की ओर से /Revenue By: Shri Bhagirath Ramawat, Sr. Dr (Virtually Present) स िवाई की िारीख / Date Of Hearing 03.09.2025 घोर्णा की िारीख/Date Of Pronouncement 22.09.2025 आदेश / O R D E R Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The Addl/Jcit (A)-2 Delhi, [Cit(A)] Dated 28.02.2025 Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For Assessment Year 2023-2024. 2. The Assessee Has Raised The Following Grounds In This Appeal.

For Appellant: Shri Prashant Ghumare, AdvFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 11Section 11(2)Section 115BSection 12ASection 143Section 143(1)Section 143(1)(a)Section 250

accumulated earlier. 16. We find some force in the arguments of the Ld. Counsel for the assessee on this issue. The provisions of section 11(2) and 11(3) of the Act as stood at the relevant time read as under: "11(1). (2) Where eighty-five per cent ... apply the aforesaid surplus for charitable purposes in AY 2008-09 and had applied for accumulation of such surplus in terms of section 11(2) of the Act. As per the provisions of section 11(2). accumulation is allowed for a period of 5 years. It is not in dispute