D.K. Jain, J.

1. This appeal by the Revenue under Section 260A of the Income Tax Act, 1961 (for short " the"), is directed against the order dated July 22, 2002, passed by the Income Tax Appellate Tribunal, Delhi Bench SMC-I, New Delhi, in I. T. A. No. 174/Delhi of 1996, pertaining to the assessment year 1992-93.

The following questions, stated to be substantial questions of law, have been proposed in the appeal memo. :

"A. Whether, on the facts and circumstances of the case, the Tribunal is justified in holding that the accumulation of income by the assessed under Section 11(2) of the Income Tax Act, 1961 (hereinafter referred to as the), for all objects for which the trust was created and not for specific purpose was neither prejudicial nor erroneous to the interests of the Revenue

B. Whether Section 11(2) of themakes it necessary for the assessed to make specific mention of any purpose or purposes to enable it to accumulate the income "

2. Briefly stated the material facts, leading to the present appeal, are that the respondent-assessed is a company registered under Section 25 of the Companies Act, 1956. It had been granted registration under Section 12A(a) of the. For the relevant previous year ending March 31, 1992, by means of a resolution, the assessed decided to accumulate its income for a period of ten years for fulfillment of the objects for which it had been created. Notice to that effect was given by filing the requisite statutory form, giving particulars of the income sought to be accumulated and invested in the specified securities. However, while completing the assessment for the relevant assessment year the Assessing Officer declined to take into consideration the amounts so accumulated on the ground that in the statutory form the specific object for which the income was sought to be accumulated was not indicated. He, accordingly, brought the said amount to tax.

3. Aggrieved the assessed preferred an appeal to the Commissioner of Income Tax (Appeals), who, by his order dated April 26, 1995, accepted the claim of the assessed. While holding that the notice to accumulate income by the assessed was in order, the Commissioner (Appeals) observed that the assessed had passed a resolution to accumulate its income so as to apply the same in India in the next ten years to achieve the object for which it had been incorporated ; notice of this fact had been given to the Assessing Officer in the prescribed format and further the said money had been invested in the specified securities. The Commissioner (Appeals), thus, held that the assessed was entitled to exemption under Section 11(1)(b) of the.

4. Being dissatisfied, the Revenue carried the matter in appeal to the Tribunal. The Tribunal has affirmed the view taken by the Commissioner (Appeals). It has also noticed that the assessed had applied the accumulated income for achieving its object. Hence, the present appeal.

5. We have heard Mr. R.D. Jolly, learned senior standing counsel for the Revenue, Mr. Jolly submits that the appellate authorities have failed to appreciate that in the prescribed form the assessed had failed to indicate the specific purpose for which the income was sought to be accumulated and, Therefore, the statutory requirement had not been strictly complied with, disentitling the assessed from relief under Section 11(2) of the.

6. We do not agree. It is true that specification of certain purpose or purposes is needed for accumulations of the trusts income under Section 11(2) of the. At the same time the purpose or purposes to be specified cannot be beyond the objects of the trust. Plurality of the purposes for accumulation is not precluded but it depends on the precise purpose for which the accumulation is intended. In the present case, both the appellate authorities below have recorded a concurrent finding that the income was sought to be accumulated by the assessed to achieve the object for which the assessed was incorporated. It is not the case of the Revenue that any of the objects of the asses-see-company were not for charitable purpose. The aforenoted finding by the Tribunal is essentially a finding of fact giving rise to no question of law.

7. We, accordingly, decline to entertain the appeal. The same is dismissed.