In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
deemed to have been used or applied for the benefit of a person referred to in sub- section (3),— (a) if any part of the income or property of the trust or institution is, or continues to be, lent to any person referred to in sub- section (3) for any period during the previous year without either adequate security