Commissioner (Appeals) had condoned the delay in filing form 10 and the Revenue had not challenged this issue. Hence, the first reasoning on which the Assessing Officer disallowed the accumulation under section 11(2) did not survive. Tribunal held that  substantial justice should be preferred to technicalities in deciding the issue. The purpose for which the amount was claimed to be accumulated was specifically mentioned in form 10 of assessment year 2016-17 as to be applied to promote and support research scientists for the advancement of research and development in future. The   the Assessing Officer is directed  to allow the consequential benefit under section 11(2) for the relevant year.(AY.2016-17, 2017-18)