N. V. BALASUBRAMANIAN, J.

There are three assessees viz. M. Ct. Muthiah Chettiar Family Trust, M.Ct. Trust and S.RM.M.Ct. M. Thiruppani Trust. The assessment years involved in all the three cases is the same viz., 1972-73. It would be sufficient to notice the facts in the case of M.Ct. Trust (hereinafter referred to as 'the assessee') as the facts in other cases are more or less similar and other cases raise identical disputes.

The assessee is a public charitable trust eligible for exemption from income-tax in accordance with the provisions of s. 11 of the IT Act, 1961 (hereinafter to be referred to as 'the Act'). The assessee in instant case, for the assessment years commencing from 1962-63 and ending on 1971-72, had been accumulating income of the trust as declared in the notice in Form 10. The income so accumulated should have been utilised for the purposes for which it was accumulated before 1st April, 1972. The purposes for which the accumulation was sought are stated as follows:

"(i) to establish and maintain and manage hospitals, clinics, laboratories and medical research centres and to provide the poor with medical relief, surgical advice and aid.

(ii) to acquire or