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The Tribunal held that since the substantive addition in the hands of the guardian was settled through a revenue scheme, the protective addition in the assessee's hands could not be sustained. The protective addition was made solely to protect the revenue's interest.
The Tribunal held that the assessee's primary and dominant object was not profit-making and that its activities were for charitable purposes and general public utility. Therefore, the assessee was entitled to exemption under Section 11.
The Tribunal dismissed the appeal as withdrawn, in light of the CBDT circular dated 8th August 2019. This circular states that appeals with a tax effect of Rs 50,00,000 or less will not be pressed by the department.