DIRECTOR OF INCOME TAX Vs. RAGHUVANSHI CHARITABLE TRUST

JUDGEMENT

(1.) The following questions of law are sought to be raised in all these appeals:

(2.) Learned Counsel for the Revenue submitted that it is not necessary to go into the facts of each case inasmuch as the aforesaid questions are pure questions of law and are related to interpretation, which has to be given to Section 11 of the Income Tax Act (hereinafter referred to as 'the Act'). The relevant portion of Section 11 of the Act reads as under:

(3.) It was the submission of Ms. Bansal that Section 11 which falls under Chapter-III is with the captioned 'Income from property held for charitable or religious purposes' and thus specifically deals with the income derived from the properties which are held by the trust wholly for charitable or religious purposes. It further stipulates that the types of income enumerated in Clause (a) to (d) of Sub-section (1) of Section 11 are not to be included in the total income of the previous years if the conditions contained in those Clauses are fulfilled. For example, in Clause (a) when it is mentioned that a particular income which is derived from property held under the trust wholly for charitable or religious purposes is not be to included if the following conditions are satisfied: