Tribunal noted that as per the unamended s.11(3), trusts had a grace period of 5 years + 1 year for utilization. 24,34,928/- to the income of the Appellant, by invoking the provisions of section 115BBI of the Act. Secondly, the money so accumulated or set apart is invested or deposited in the forms or mode specified in section 11(5). It, inter alia, provides that if the accumulated income is not applied within 5 years, it shall be taxed in the 6th year. 24,34,928/- utilised during the year being the grace year (6thyear) in terms of the provisions existing at the time of accumulation.