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“Section 11(5)”

Section References (mined)Section 11Section 11(5)316 judgments

The decision most relied on for Section 11(5) is PCIT v. Wipro Ltd. (140 Taxmann.com 223), cited in 192 judgments on BharatTax.

Leading authorities on Section 11(5)

PCIT v. Wipro Ltd.
140 Taxmann.com 223 · 2022 · Supreme Court
192
citing judgments

Exemption provisions under Chapter III, such as Section 10B(8), must be interpreted strictly, and any claim for such exemptions must be made in the return of income. The principles governing Chapter III (incomes not forming part of total income) differ from those for Chapter VIA (deductions in computing total income).

Lissie Medical Institutions v. CIT
348 ITR 344 · 2012 · High Court
164
citing judgments

The Kerala High Court held that charitable institutions claiming exemption under Section 11 are not entitled to claim depreciation on assets used for charitable purposes, taking a view contrary to most other High Courts.

CIT v. Fr. Mullers Charitable Institutions
363 ITR 230 · 2014 · High Court
117
citing judgments

For a charitable trust, a violation of Section 13(1)(d) does not lead to the denial of exemption under Section 11 on its total income. Instead, only income derived from investments or deposits made in violation of Section 11(5) or income diverted under Section 13(1)(c) or 13(1)(d) is taxable.

1. Father Mullers Charitable Institutions 363 IT 230 (Kar.) 2. DIT(E) v. Sheth Mafatlal Gagalbhai Foundation Trust
249 ITR 533 · 2001 · High Court
108
citing judgments

Income of a trust that is taxable at the maximum marginal rate should be taxed accordingly, while other income is eligible for exemption under Section 11 of the Income-tax Act.

Commissioner of Income-tax v. Nizam's Suppl. Religious Endowment Trust
127 ITR 378 · 1981 · High Court
87
citing judgments

Income of a charitable trust, other than from a business undertaking covered by Section 11(4), is determined based on its books of account. Payments of income tax and wealth tax by the trust are considered an application of income for charitable purposes under Section 11.

CIT v. Dawoodi Bohra Jamat
364 ITR 31 · 2014 · Supreme Court
83
citing judgments

A trust's objects, even if based on religious tenets, can qualify as charitable for tax exemptions if its benefits are not exclusively restricted to a particular religious community or caste.

Trust (249 ITR 533) (Bom.) 3. CIT vs. Red Rose School (163 Taxman 19 (All.) 4. DIT(E) v. Alarippu (
172 ITR 698 · 1988 · High Court
61
citing judgments

Income received by a trust from sources like extra fees can be taxed at the maximum marginal rate, while other income remains eligible for exemption under Section 11 of the Income Tax Act.

Dy. CIT v. Zuari Estate Development and Investment Co. Ltd.
373 ITR 661 · 2015 · Supreme Court
61
citing judgments

Reopening of assessment beyond four years under Section 147 requires strict satisfaction of conditions precedent, including fresh tangible material, and cannot be based on a mere change of opinion from the original assessment. Further, debatable or interpretational issues cannot be adjusted during processing under Section 143(1).

Judgments citing Section 11(5)

Guru Teg Bahadur Educational Trust, Jalandhar vs. Commissioner of Income Tax ( Exemptions), Chandigarh

In the result, appeal of the assessee is allowed

ITA 264/ASR/2022[2017-18]Status: DisposedITAT Amritsar14 Mar 2023AY 2017-18

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. K. Bhagat, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 12ASection 5

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR (VIRTUAL COURT) BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH

Navbharat Charitable Trust, Bharuch vs. Income Tax Officer, Ward - 1, Bharuch

In the result, this appeal of the assessee is allowed for statistical purposes

ITA 385/SRT/2022[2019-20]Status: DisposedITAT Surat28 Feb 2023AY 2019-20

Bench: Shri Pawan Singhita No. 383, 384 & 385/Srt/2022 (Assessment Years: 2017-18, 2018-19 & 2019-20) (Hearing In Virtual Court) Navbharat Charitable Trust, I.T.O., 0, Rajpardi, Jhagadia, Ward-1, Vs. Bharuch. Bharuch. Pan No. Aactn 0979 K Appellant/ Assessee Respondent/ Revenue

Section 11Section 12ASection 13(10)Section 254(1)Section 80G

trust income for specific purpose, the assessee has set apart the income of the trust in the the forms or modes specified in section 11(5) "Where 85% of the income of charitable trust as referred above is not applied to charitable or religious purposes in India during the previous ... such a huge period of almost 5 years. Moreover, the assessee has not submitted any details and evidences showing that the provisions of section 11(5) r.w.s. 11(2) are fully complied with more particularly the investment of accumulated funds was in specified modes only. Thus compliance of the provisions

Navbharat Charitable Trust, Bharuch vs. Income Tax Officer, Ward - 1, Bharuch

In the result, this appeal of the assessee is allowed for statistical purposes

ITA 384/SRT/2022[2018-19]Status: DisposedITAT Surat28 Feb 2023AY 2018-19

Bench: Shri Pawan Singhita No. 383, 384 & 385/Srt/2022 (Assessment Years: 2017-18, 2018-19 & 2019-20) (Hearing In Virtual Court) Navbharat Charitable Trust, I.T.O., 0, Rajpardi, Jhagadia, Ward-1, Vs. Bharuch. Bharuch. Pan No. Aactn 0979 K Appellant/ Assessee Respondent/ Revenue

Section 11Section 12ASection 13(10)Section 254(1)Section 80G

trust income for specific purpose, the assessee has set apart the income of the trust in the the forms or modes specified in section 11(5) "Where 85% of the income of charitable trust as referred above is not applied to charitable or religious purposes in India during the previous ... such a huge period of almost 5 years. Moreover, the assessee has not submitted any details and evidences showing that the provisions of section 11(5) r.w.s. 11(2) are fully complied with more particularly the investment of accumulated funds was in specified modes only. Thus compliance of the provisions

Navbharat Charitable Trust, Bharuch vs. Income Tax Officer, Ward - 1, Bharuch

In the result, this appeal of the assessee is allowed for statistical purposes

ITA 383/SRT/2022[2017-18]Status: DisposedITAT Surat28 Feb 2023AY 2017-18

Bench: Shri Pawan Singhita No. 383, 384 & 385/Srt/2022 (Assessment Years: 2017-18, 2018-19 & 2019-20) (Hearing In Virtual Court) Navbharat Charitable Trust, I.T.O., 0, Rajpardi, Jhagadia, Ward-1, Vs. Bharuch. Bharuch. Pan No. Aactn 0979 K Appellant/ Assessee Respondent/ Revenue

Section 11Section 12ASection 13(10)Section 254(1)Section 80G

trust income for specific purpose, the assessee has set apart the income of the trust in the the forms or modes specified in section 11(5) "Where 85% of the income of charitable trust as referred above is not applied to charitable or religious purposes in India during the previous ... such a huge period of almost 5 years. Moreover, the assessee has not submitted any details and evidences showing that the provisions of section 11(5) r.w.s. 11(2) are fully complied with more particularly the investment of accumulated funds was in specified modes only. Thus compliance of the provisions

M/S. Gopal Govardhan Goshala, Sanchore, Jalore vs. DCIT, Circle-Exemption, Jodhpur

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

ITA 189/JODH/2019[2014-15]Status: DisposedITAT Jodhpur20 Jan 2023AY 2014-15

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmim/S. Gopal Goverdhan Goshala Vs The Dcit Pathmeda, Taluka Sanchore, Circle-Exemption, District- Jalore (Raj) Jodhpur (Appellant) (Respondent) Pan No. Aaatg 0739 J

Section 11Section 11(2)(b)Section 11(5)Section 12ASection 13(1)Section 13(1)(d)Section 40Section 40A(3)

modes prescribed u/s 11(5) of the Act and hence, as such, there was no violation of provisions of section 11(5) of the Act. He also submitted the requirement of making investment in the modes prescribed in section 11(5) shall be applicable only to the income accumulated ... such violation of provisions of the Act as alleged by the AO. It was submitted that there is no violation of Section 11(5) of the Act, as making investment in immovable property is one of the modes prescribed under the Act and further, the investment in agricultural land, though

Pradeep Kumar, Jhujhunu vs. ITO Ward -2, Jhujhunu

In the result, appeal of the assessee is allowed

ITA 370/JPR/2022[2011-12]Status: DisposedITAT Jaipur11 Jan 2023AY 2011-12

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Ms Monisha Choudhary (JCIT)
Section 142(1)Section 143(3)Section 147Section 148Section 234A

Rate in terms of proviso to Section 164(2)—Total amount was treated as income by invoking Section 13(1)(b) read with Section 11(5)— 11 Shri Pradeep Kumar, Jhunjhunu. Amount said to have received as donation was added back to income of assessee under Section

M/S. Srinivas Institute of Medical Science and Research Centre, Mangalroe vs. The Principal Commissioner of Income Tax (Central), Bengaluru

In the result, the appeal filed by the assessee is allowed

ITA 533/BANG/2022[N/A]Status: DisposedITAT Bangalore30 Dec 2022

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: N.A.

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Dr. G. Manoj Kumar, D.R
Section 10Section 11Section 12ASection 269S

circumstances of the appellant's case. 7. The learned Pr.CIT, Bangalore erred in holding that there is a violation of the provisions of Section 11 [5] and Section 269SS of the Act under the facts and in the circumstances of the appellant's case. The learned Pr.CIT, Bangalore ought ... collection of fee, capitation receipt etc over a period of time which was kept at home. This is clearly in violation of Section 11(5) of the Act. The cash seized at the residential premises of the Trustee ii) confirms the diversion of Trust funds to the trustees. Inspection

Parab Maratha Samaj, Mumbai vs. National Faceless Assessment Centre, Delhi

In the result, the appeal filed by the assessee stands partly allowed

ITA 1821/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 Nov 2022AY 2019-20

Bench: Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1821/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) Parab Maratha Samaj, Nfac, Delhi बिधम/ 10, 5Th Floor Mahohar Bldg, Priti Kanha, Chitable Path, Vs. Dadar(W), Mumbai-400 028 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaatp4197P (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Dinesh Shah, Ld. Ar प्रत्यथीकीओरसे/Respondent By : Ms. Neeta Jeph, Ld. Dr सुनवाईकीतारीख/ : 01.09.2022 Date Of Hearing घोषणाकीतारीख / : 30.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 09.05.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi For The Quantum Of Assessment Passed U/S 143(3) For Ay 2019-20. The Assessee Has Raised The Following Grounds Of Appeal:-

For Appellant: Shri Dinesh Shah, Ld. ARFor Respondent: Ms. Neeta Jeph, Ld. DR
Section 11Section 12ASection 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM आयकरअपीलसं./ I.T.A. No. 1821/Mum/2022 (निर्धारणवर्ा / Assessment

The Goa Hindu Association, Mumbai vs. ITO (Exemption)-2(4), Mumbai

In the result, the present appeal is allowed

ITA 1723/MUM/2020[2015-16]Status: DisposedITAT Mumbai21 Oct 2022AY 2015-16
For Appellant: Shri Shankar JalgarFor Respondent: Shri Rajiv Singh
Section 11(2)Section 11(2)(a)Section 11(5)Section 12ASection 143(1)Section 154

invested the amount ITA. No. 1723/Mum/2020 Assessment Year: 2015-16 accumulated in Fixed Deposit with Scheduled Banks as per the requirement of Section 11(5) of the Act and had claimed benefit of Section 11(2) of the Act in respect of the same. The return filed by the Appellant

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1831/MUM/2022[2011-12]Status: DisposedITAT Mumbai30 Sept 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

claiming exemption of income-A.O. held that amount given to M/s ‘A’ Ltd. as advance infringes provision of section 11(5) and hence, said amount was liable to be taxed-During pendency of appeal before CIT(A), Commissioner in exercise of his suo-motu power u/s 263 held that ... view of violation of Section 11(5) entire income of assessee Trust, ought to have been assessed and they are not entitled for any exemption u/s 11 and 12 Tribunal set aside order passed by Commission-Held, Commissioner cannot invoke his revisional power to correct each and every mistakes committed

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1830/MUM/2022[2010-11]Status: DisposedITAT Mumbai30 Sept 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

claiming exemption of income-A.O. held that amount given to M/s ‘A’ Ltd. as advance infringes provision of section 11(5) and hence, said amount was liable to be taxed-During pendency of appeal before CIT(A), Commissioner in exercise of his suo-motu power u/s 263 held that ... view of violation of Section 11(5) entire income of assessee Trust, ought to have been assessed and they are not entitled for any exemption u/s 11 and 12 Tribunal set aside order passed by Commission-Held, Commissioner cannot invoke his revisional power to correct each and every mistakes committed

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1829/MUM/2022[2009-10]Status: DisposedITAT Mumbai30 Sept 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

claiming exemption of income-A.O. held that amount given to M/s ‘A’ Ltd. as advance infringes provision of section 11(5) and hence, said amount was liable to be taxed-During pendency of appeal before CIT(A), Commissioner in exercise of his suo-motu power u/s 263 held that ... view of violation of Section 11(5) entire income of assessee Trust, ought to have been assessed and they are not entitled for any exemption u/s 11 and 12 Tribunal set aside order passed by Commission-Held, Commissioner cannot invoke his revisional power to correct each and every mistakes committed

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1828/MUM/2022[2008-09]Status: DisposedITAT Mumbai30 Sept 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

claiming exemption of income-A.O. held that amount given to M/s ‘A’ Ltd. as advance infringes provision of section 11(5) and hence, said amount was liable to be taxed-During pendency of appeal before CIT(A), Commissioner in exercise of his suo-motu power u/s 263 held that ... view of violation of Section 11(5) entire income of assessee Trust, ought to have been assessed and they are not entitled for any exemption u/s 11 and 12 Tribunal set aside order passed by Commission-Held, Commissioner cannot invoke his revisional power to correct each and every mistakes committed

Rajiv Gandhi University of Health Sciences, Bangalore vs. The Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal filed by the assessee in ITA No

ITA 584/BANG/2022[2016-17]Status: DisposedITAT Bangalore29 Sept 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Mrs. Suman Lunkar, CAFor Respondent: Smt. S. Praveena, CIT DR
Section 10Section 10(23)(C)Section 11(2)Section 11(5)Section 12ASection 143(2)Section 154Section 234B

learned CIT(A), NFAC has erred in confirming the same on the ground that the Appellant had not complied with the provisions of section 11(5) of the Act. The conclusion drawn being wholly erroneous. both on facts and law applicable, is to be deleted. 2.2 In any case ... Authorities below have erred in not appreciating the fact that the Appellant having complied with the provisions of section 11(5) of the Act by investing the accumulation made u/s 11(2) of the Act in the specified Page 3 of 15 ITA Nos. 584 & 563/Bang/2022 investments has rightly claimed

Rajiv Gandhi University of Health Sciences, Bangalore vs. The Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal filed by the assessee in ITA No

ITA 563/BANG/2022[2016-17]Status: DisposedITAT Bangalore29 Sept 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Mrs. Suman Lunkar, CAFor Respondent: Smt. S. Praveena, CIT DR
Section 10Section 10(23)(C)Section 11(2)Section 11(5)Section 12ASection 143(2)Section 154Section 234B

learned CIT(A), NFAC has erred in confirming the same on the ground that the Appellant had not complied with the provisions of section 11(5) of the Act. The conclusion drawn being wholly erroneous. both on facts and law applicable, is to be deleted. 2.2 In any case ... Authorities below have erred in not appreciating the fact that the Appellant having complied with the provisions of section 11(5) of the Act by investing the accumulation made u/s 11(2) of the Act in the specified Page 3 of 15 ITA Nos. 584 & 563/Bang/2022 investments has rightly claimed

Lions Club of Malad Borivali Charity Trust, Mumbai vs. CIT Exemptions, Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 1458/MUM/2022[2017-18]Status: DisposedITAT Mumbai27 Sept 2022AY 2017-18

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2017-18 Lions Club Of Malad Borivali Cit Exemptions, Charity Trust, 601,6Th Floor, Cumballa Hills, Pd Lions College, Sv Road, Vs. Mumbai-400026. Sunder Nagar, Malad West, Mumbai-400064. Pan No. Aaatl 1407 C Appellant Respondent Assessee By : Mr. Shankarlal Jain, Ar Revenue By : Ms. Shailja Rai, Cit-Dr Date Of Hearing : 24/08/2022 Date Of Pronouncement : 27/09/2022

For Appellant: Mr. Shankarlal Jain, ARFor Respondent: Ms. Shailja Rai, CIT-DR

these tunds have been invested in verified whether the balance in these tunds have been invested in modes specified under the provisions of Section 11(5) of the Act? Non odes specified under the provisions of Section 11(5) of the Act? Non odes specified under the provisions of Section ... funds The AO may verify whether the investment of balance in the funds have been made in the modes specified in Section 11(5) of een made in the modes specified in Section 11(5) of een made in the modes specified in Section 11(5

Vile Parle Mahila Sangh, Mumbai-400057 vs. Commissioner of Income Tax (Exemptions), Mumbai-400026

In the result, appeal filed by the assessee is allowed

ITA 1066/MUM/2022[2017-18]Status: DisposedITAT Mumbai21 Sept 2022AY 2017-18

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Ms Kavitha Rajagopal, Hon'Blevile Parle Mahila Sangh V. Cit (Exemptions) Mangalayatan, Paranjpe B Scheme Room No. 601, 6Th Floor Road No. 1, Vile Parle (E) Mtnl Te Building, Pedder Road Mumbai - 400057 Dr. Gopal Rao Deshmukh Marg Cumballa Hill, Mumbai – 400026 Pan: Aaatv2407Q (Appellant) (Respondent) Assessee Represented By : Mandar Vaidya Department Represented By : Achal Sharma

Section 11(2)Section 119(2)Section 12ASection 139Section 143(3)Section 263

Rs.1,20,02,003/- accumulated for the purpose of construction of school building by keeping the money invested in the mode stipulated under section 11(5). The trust has also not written back the accumulation in its books of accounts. The addition and levy of tax would be unfair

M/A Adinath Jain Trust, Chennai vs. ITO, Exemptions Ward-2, Chennai

In the result, appeals filed by the assessee for both the

ITA 85/CHNY/2022[2017-18]Status: DisposedITAT Chennai14 Sept 2022AY 2017-18

Bench: Shri G.Manjunathaआयकरअपीलसं./I.T.A.No.84 & 85/Chny/2022 ("नधा"रणवष" / Assessment Years:2016-17 & 2017-18) Vs The Income Tax Officer, M/S.Adinath Jain Trust Exemptions Ward-2, 21, V.V.Koil Street, Choolai, Chennai. Chennai-600 112. Pan: Aaata 6919J (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. N.Sanjay Gandhi, Addl.CIT
Section 11Section 12ASection 13(1)Section 13(1)(d)

various facts held that the assessee has violated provisions of section 13(1)(d) by advancing loans & advances in violation of provisions of section 11(5) of the Act, and thus, opined that the Assessing Officer is right in rejection of exemption u/s.11 of the Act. The learned

M/S Adinath Jain Trust, Chennai vs. ITO Exemptions, Ward-2, Chennai

In the result, appeals filed by the assessee for both the

ITA 84/CHNY/2022[2016-17]Status: DisposedITAT Chennai14 Sept 2022AY 2016-17

Bench: Shri G.Manjunathaआयकरअपीलसं./I.T.A.No.84 & 85/Chny/2022 ("नधा"रणवष" / Assessment Years:2016-17 & 2017-18) Vs The Income Tax Officer, M/S.Adinath Jain Trust Exemptions Ward-2, 21, V.V.Koil Street, Choolai, Chennai. Chennai-600 112. Pan: Aaata 6919J (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. N.Sanjay Gandhi, Addl.CIT
Section 11Section 12ASection 13(1)Section 13(1)(d)

various facts held that the assessee has violated provisions of section 13(1)(d) by advancing loans & advances in violation of provisions of section 11(5) of the Act, and thus, opined that the Assessing Officer is right in rejection of exemption u/s.11 of the Act. The learned

Archana Foundation, Mumbai vs. Income Tax Officer Exemptions 1(1), Piramal Chambers Mumbai

In the result, appeal filed by the assessee is allowed

ITA 1431/MUM/2021[2017-18]Status: DisposedITAT Mumbai05 Sept 2022AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalarchana Foundation More House 28, New India Housing Society North South Road No.11, Jvpd, Juhu, Mumbai-400049. Pan: Aabta0873E ...... Appellant Vs. Ito (Exemption)-1(1), Piramal Chambers, Lalbaug, Mumbai-400012. ..... Respondent Appellant By : Sh. Amit Agrawal Respondent By : Sh. Pramod Nikalje Date Of Hearing : 13/06/2022 Date Of Pronouncement : 05/09/2022 Order Per Gagan Goyal, A.M:

For Appellant: Sh. Amit AgrawalFor Respondent: Sh. Pramod Nikalje
Section 11(1)Section 11(2)Section 12A

purchase property for furtherance of activities and objects of assessee, and assessee had invested said accumulation of income in one mode prescribed under section 11(5) by taking FDR's with banks - Moreover, assessee did purchase property in immediately succeeding financial year and aforesaid accumulation of income under section 11