Appeals are allowed
Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member
purchased a refrigerator and kept it at the residence of its managing trustee. As the trustee was enjoying the use of the property of the trust, the ITO held that the provisions of Section 13 were attracted. The Court observed that from a bare reading of the provisions, it can be inferred that the legislative emphasis is on availability