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10. We do not think that this is the correct way to distinguish a decision of a superior court. The Tribunal has first to see what is the law laid down and then apply it to the facts of a given case. What has been done by the Tribunal in this case is that it has noted that the facts of the cited case is different and has not discussed the law laid down. This is not the correct approach for determining whether a decision is distinguishable or not.

11. Our attention has been drawn to the Commissioner of Income Tax v. Hotel and Restaurant Association . On a reading of this judgment, we find that it has been held by this Court that it is not necessary for a charitable trust to particularize each and every object for which accumulation is sought. It is enough if the assessed seeks accumulation for the objects of the trust. In the case at hand, the assessed has gone a step further and has specified each and every object for which accumulation is sought.