Assessee, a charitable trust registered under section 12A, filed return of income for the relevant year claiming exemption under section 11, including benefit of accumulation under section 11(2), which was accepted in assessment. Subsequently, Assessing Officer issued notices under sections 148A(b) and 148 on ground that assessee had not complied with provisions of section 11(2), as it had not specified exact purpose for which income was accumulated-It was noted that assessee had filed prescribed Form No. 10 on or before due date specified under section 139(1), stating that accumulation was made as per objects of trust and, having regard to limited space provided in Form No. 10 prescribed under Rule 17, had specifically referred to trustees’ resolution setting out three purposes for accumulation. These purposes, though multiple, were specific, were within scope of assessee-trust’s objects and were charitable in nature, and a copy of such resolution was available on record prior to passing of assessment order. Since mandatory requirements of section 11(2) stood fulfilled, income could not be said to have escaped assessment and, therefore, notices issued under sections 148A(b) and 148 and order passed under section 148A(d) were unsustainable. Once the conditions of section 11(2) were satisfied, accumulated income could not be included in total income, and the Assessing Officer had no discretion to deny such benefit. Reassessment notice and consequential order were quashed and set aside.    (AY. 2018-19)