COMMISSIONER OF INCOME TAX Vs. DHARMODAYAM COMPANY

JUDGEMENT

(1.) A reference is at the instance of the Revenue from the order of the Income-tax Appellate Tribunal, Cochin Bench in I.T.A. No. 264/Coch. of 1989. Relevant assessment year is 1985-86. Following are the questions raised for the opinion of this court :

(2.) WHETHER, on the facts and in the circumstances of the case, the Tribunal is right in law in holding that 'the business is carried on for carrying out the primary objects of the trust and it will not be hit by the provisions of Section 11(4A) of the Income-tax Act' and is not the above finding wrong, unreasonable and unwarranted considering the scope and object of Section 11(4A) of the Income-tax Act, 1961 ?"