JUDGMENT judgment of court was delivered by Sanjiv Khanna J.-This appeal by Revenue pertains to assessment year 1996-97 and was admitted for hearing by order dated November 6, 2006, on following substantial question of law: "Whether Income-tax Appellate Tribunal was correct in holding that by mentioned (sic mentioning)'further utilisation' in Form No. 10 read with rule 17 of Income-tax Rules, 1962, assessee has fulfilled its obligation as required under section 11(2) of Act?" respondent-society claiming itself to be charitable institution had filed return of income for assessment year 1996-97 declaring nil taxable income. respondent also filed Form No. 10 along with its return as required by section 11(2) of Act. During course of assessment proceedings, Assessing Officer, after going through return and Form No. 10, noticed that respondent-assessee had accumulated Rs. 27,54,839 for description/purpose "further utilisation". said purpose/description, it was observed was not specific one, accordingly, respondent-assessee was asked to explain why accumulation under section 11(2) of Act should not be disallowed. respondent-assessee, vide its letter dated February 22, 1999, submitted their explanation that accumulation was done for aims and objectives of society. Assessing Officer, after going through reply of respondent assessee, held that explanation of assessee was vague and purpose "further utilisation" cannot be treated as accumulation for specific purpose. He observed that Form No. 10, filed by respondent- assessee, did not meet statutory mandate as definite and concrete purpose/purposes should have been specifically stated in Form No. 10. Accordingly, Assessing Officer disallowed accumulation under section 11(2) and added it to total income of assessee. Commissioner of Income-tax (Appeals) upheld view of Assessing Officer and rejected contention of assessee that expression "further utilisation" was in context of objects of charity, i.e., as per objectives for which respondent-society was formed. He observed that accumulation or setting apart income in context of objectives alone would not meet statutory requirements under section 11(2) of Act. purpose for which it had been accumulated should be definite and specified. On further appeal, Income-tax Appellate Tribunal ("the Tribunal", for short) reversed said findings. Tribunal observed that assessee had mentioned words "further utilisation" in column No. 1 of Form No. 10, which meant that assessee was to utilise funds for benefit of members, i.e., employees of New Bank of India in case of death, retirement and permanent disability. They referred to very object for which respondent- society was formed. It was recorded that funds were paid/given to employees of New Bank of India in aforesaid eventualities and it was in this context, words "further utilisation" had been mentioned. Referring to objectives of society, it was observed that respondent-assessee was to provide financial assistance to members in case of death, retirement and permanent disability. This was sole and only purpose for which funds could be utilised. It was held that description "further utilisation" was neither vague nor unspecific. Tribunal distinguished decision of Calcutta High Court in Director of Income-tax (Exemption) v. Trustees of Singhania Charitable Trust [1993] 199 ITR 819 (Cal) on ground that in said case, charitable trust had as many as 18 objectives and there was no specific objective for which accumulation had been sought. Further, in this case, objectives of respondent-society were clear and specific and sole objective being that funds should be used for purpose of providing financial assistance to members in case of death, retirement and permanent disability. It is obvious that purpose and objective behind section 11(2) of Act is to curtail long-term accumulation of income by charitable institutions without specifying purpose for which funds were being accumulated. accumulation is permitted provided assessee specifies purpose or purposes for which accumulation is required and necessary. question whether and in which cases declaration regarding purpose of accumulation given by assessee should be treated as sufficient was examined by Delhi High Court in CIT v. Hotel and Restaurant Association [2003] 261 ITR 190 (Delhi). contention raised by Revenue in said case was that Tribunal had failed to appreciate that in prescribed form, assessee has failed to indicate specific purpose for which income was sought to be accumulated and, therefore, assessee had violated section 11(2) of Act. contention was rejected in following words (page 192): "We do not agree. It is true that specification of certain purpose or purposes is needed for accumulations of trust's income under section 11(2) of Act. At same time purpose or purposes to be specified cannot be beyond objects of trust. Plurality of purposes for accumulation is not precluded but it depends on precise purpose for which accumulation is intended. In present case, both appellate authorities below have recorded concurrent finding that income was sought to be accumulated by assessed to achieve object for which assessed was incorporated. It is not case of Revenue that any of objects of assessee-company were not for charitable purpose. aforenoted finding by Tribunal is essentially finding of fact giving rise to no question of law." decision in Hotel and Restaurant Association (supra) was referred to in another decision of Delhi High Court in Bharat Kalyan Pratisthan v. DIT (Exemption) [2008] 299 ITR 406 (Delhi) and it was observed that in Hotel and Restaurant Association's case (supra) this court had observed that if accumulation was for one or more purposes and these purposes were objects of institution, then it is permissible for assessee to accumulate income for utilisation of these objects. Reference was also made to DIT (Exemption) v. Daulat Ram Education Society [2005] 278 ITR 260 (Delhi) wherein assessee had specified eight purposes under section 11(2) of Act. This it was held was permissible. Thereafter, High Court observed as under (page 409 of 299 ITR): "In present case, assessee has only three objects as far as its trust deed, copy of which has been placed on record, is concerned. trust deed requires trust to utilise its funds for charitable purposes which are medical relief, education and relief to poor. In application seeking exemption, assessee had specified these three objects. We are of opinion that it was not required for assessee to be more specific with regard to utilisation of funds." In case of DIT (Exemption) v. Mamta Health Institute for Mother and Children [2007] 293 ITR 380 (Delhi), High Court referred to objectives for which society was formed which had seven clauses. Revenue had alleged that in Form No. 10, assessee had failed to indicate specific purpose for which income was sought to be accumulated, but this submission was rejected by observing that assessee had placed copy of annual report in which he has specified items for which money was accumulated. It was, accordingly, observed (page 383): "A perusal of annual report as well as overview of these projects clearly shows that projects were in consonance with objectives sought to be achieved by assessee, which were for benefit of women and adolescent girls particularly in slums or in community which was not particularly well off. On going through objects of society, it is clear that assessee sought to accumulate funds for charitable purpose. Quite clearly, Tribunal was correct in its conclusion that decision of this court would apply to facts of case and that assessee was entitled to benefit of accumulation. We do not find any infirmity in order passed by Tribunal. No substantial question of law arises for consideration." In present case, Assessing Officer himself had noted in assessment order that aim and objective of assessee was to work for welfare of employees of New Bank of India. This undoubtedly was purpose and objective of society. Therefore, during course of assessment proceedings as is apparent from appellate proceedings, assessee has clarified and stated that money in question would only be used for purpose of making payments to members or their legal representatives in case of their death, retirement or permanent disability. Tribunal in impugned order has also referred to scheme floated by respondent-assessee under which employees who were desirous of becoming members had to deposit Rs. 10 as admission fees and, thereafter, pay Rs. 25 per month for period of 25 years. scheme devised provided: "Present scheme Membership: Membership of society shall be open to permanent employees of New Bank of India. Any employee desirous of becoming member may apply on prescribed form on payment of Rs. 10 as admission fee, duly recommended by any of office bearer or managing committee member of society employees appointed on part time basis and one-third or two-thirds salary are not eligible for membership. Subscription: Under present scheme, every member shall subscribe sum of Rs. 25 per month for period of 25 years. Benefits: (a) in case of death: (i) members in age group of below 50 years (as on 31-7-85) will be entitled to following benefits: (a) sum of Rs. 500 p.m. shall be paid to nominee of deceased member for period of 15 years. (b) Lump sum additional payment of Rs. 15,000 shall be made to nominee of deceased member in addition in benefit referred to above if member dies during period of service in bank. (ii) members in age group of above 50 years (as on 31-7-1985) will be entitled to following benefits: (a) sum of Rs. 500 p.m. shall be paid to nominee of deceased member till age of retirement with minimum period of 5 years. (b) lump sum payment of Rs. 15,000 shall be made to nominee of deceased member in addition to benefit referred above (iia) if member dies during period of service in bank. Other benefits are also there which are in case of retirement and these have been given in part "B" of this scheme to extent that sum of Rs. 500 per month shall be paid to members as per calculation given in same. Further, other benefits in cases of death and permanent disability have also been given. Lastly, benefit have been given on resignation from bank prior to retirement. contention of learned counsel is that this is only object of assessee and there are no plurality of objects and as such if assessee had mentioned in Form No. 10 that accumulation of funds were for'further utilisation' very purpose is to utilise amount of accumulation for further benefits to be given to members in case of death, retirement, permanent disability..." Other benefits which were specified in part (b) of scheme, which stipulated that sum of Rs. 500 shall be paid to members on event specified therein. aforesaid contention has been accepted by Tribunal. findings recorded are in consonance with ratio of several decisions of this court. In view of factual background, substantial question of law in terms of decisions of this court has to be answered in favour of respondentassessee and against appellant. appellant-Revenue is not entitled to succeed. appeal is disposed of. There will be no order as to costs. *** Director of Income-tax (Exemption) v. NBIE Welfare Society