Bench: Shri P. M. Jagtap(Kz) & Shri A. T. Varkey]
Charitable Trust (supra) has held on this issue as under: “6. We have heard learned Senior Counsel Mr.Kumar and Mr.A.Shankar, appearing for the appellants and Mr.K.V.Aravind, learned counsel appearing for Income Tax Department. 7. We may at the outset record that, learned counsel appearing for both sides have made submissions which shall be dealt with appropriately at the later stage