Whether income accumulation under section 11 (2) for capital expenditure was added to total revenue and surplus once again accumulated , whether total accumulation be taxed ?

A charitable trust set apart certain amounts u/s 11(2) for FY 2012-13 for investment in Capital expenditure on Buildings. In years thereafter the trust kept incurring Capital expenditure on buildings but did not set off the accumulated amount against such capital expenditure. In FY 2017-18 the accumulated amount was added to the other revenue and its utilisation towards revenue and capital expenditure was adjusted against total revenue. Some surplus was again accumulated u/s 11(2) for FY 17-18. The AO wishes to tax the total accumulation for FY 12-13 u/s 11(3) and denying the benefit of expenditure on revenue and capital…

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