In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

disallowed and entire exemption under section 11 cannot be denied. Section 13 spells out certain circumstances in which the exemption provided under section 11/ 12 is not applicable. Further, Section 164(2) and 164(3) which reads as under:- “[(2) In the case of relevant income which is derived from property held under trust wholly for charitable or religious purposes