Medical Education And Research Charitable Trust v CIT(E) (2023) 107 ITR 71 (Mum.)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Failure to specify exact purpose of accumulation of income-Purpose of accumulation not beyond objects of assessee-Revision is not justified.[S.11(2), 142(1), 143(3), Form No 10.]

Held that all the technical requirements were duly fulfilled by the assessee, along with a satisfactory response to the queries raised through notice under section 142(1) during the original assessment. The only objection raised by the Commissioner (E) through notice issued under section 263 was that the assessee had not specifically mentioned the purpose of accumulation of income. The assessee had placed on record form 10 furnished before the Assessing Officer specifying the purpose, amount, and period of accumulation. In any case, the purpose of accumulation could not be beyond the objects of the assessee. The assessee is not required to mention the “exact purpose” of accumulation. Revision is held to be not justified. (AY.2018-19)