Held that  once the assessee had reinvested the sale consideration for acquiring another capital asset, the whole capital gains are exempt under section 11(1A) of the Act. The assessee is eligible for exemption. Tribunal also held that   an appeal being a continuation of original proceedings, the appellate authority had co-terminous and co-extensive powers as the Assessing Officer. Therefore, when the assessee had filed form 10 before the Commissioner (Appeals), he ought to have admitted it to consider accumulation of income under section 11(2) of the Act. Accumulation of income under section 11(2) of the Act is a beneficial provision allowed to an assessee in case the assessee-trust or institution is not able to apply its income in full during the relevant financial year. Therefore, while considering the beneficial provision, the Commissioner (Appeals) should have considered the issue without going into technicalities or procedural lapses. Followed   CIT v. Hardeodas agarwalla trust (1992) 198 ITR 511 (Cal)(HC). (AY.2015-16)