Charitable exemption for kuri business income upheld under section 11(1), with section 11(4A) not displacing relief.

Income from a charity's kuri business was held eligible for exemption under section 11(1) of the Income-tax Act, 1961, because section 11(4A) did not defeat that exemption on the facts found. The court followed its earlier finding in the assessee's own case and treated the business income as continuing to qualify for exemption. The question was answered in favour of the assessee and against the Revenue.

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Issues: Whether the assessee was entitled to exemption under section 11(1) of the Income-tax Act, 1961 in respect of income from its kuri business notwithstanding section 11(4A) of the Income-tax Act, 1961.

Analysis: The issue had already been considered in the assessee's own case for an earlier reference. The controlling finding was that the income from the kuri business remained eligible for exemption under section 11(1), and the restriction in section 11(4A) did not defeat that exemption on the facts found.

Conclusion: The question was answered in the affirmative, in favour of the assessee and against the Revenue.

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