Assessee-society, namely EHIRC, Delhi, was formed in year 1981 and, its objects were charitable in nature. Income of assessee was exempt under section 10(21)-In year 1999, another society by name of EHIRC, Chandigarh was formed which was not a charitable society. Assessee merged with EHIRC, Chandigarh, under due process of law and all its assets and liabilities vested with latter. For relevant year, assessee did not file return of income. AO having regard to amalgamation of assessee with EHIRC, Chandigarh, completed assessment making addition of accumulated profit to assessee’s income. Tribunal held that since revenue failed to bring any evidence on record to establish accumulation of profit under section 11(2) by assessee-society in earlier assessment year, impugned addition made by AO set aside.  (AY. 2001-02)