In the result, both the appeals filed by the assessee are allowed
Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra
Charitable Trust (2001) (247 ITR 1) … iv. The Hon'ble Bombay High Court in L.R. Patel Family Trust vs. ITO (2003) (262 ITR 520) … v. The Hon'ble Delhi High Court in CIT vs. SAE Head Office Monthly Paid Employee Welfare Trust (2004) (271 ITR 159) … vi. The Hon'ble Tribunal in Sriram Trust, Hyderabad vs Income Tax Officer