Section 11 exemption for trust business income denied where statutory conditions under section 11(4A) were not met.

Income from business activities of a charitable trust qualified for exemption under section 11 only if the case fell within the limited categories in section 11(4A): a trust for public religious purposes carrying on the specified business, or an institution wholly for charitable purposes where the business work was mainly carried on by the beneficiaries and separate books were maintained. The trust did not satisfy either statutory category because it was neither a trust for public religious purposes nor an institution within the provision. Exemption under section 11 was therefore unavailable for the assessment years concerned.

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Issues: Whether the assessee charitable trust was entitled to exemption under section 11 of the Income-tax Act, 1961 for the assessment years 1984-85 and 1985-86 in view of section 11(4A).

Analysis: The income in question arose from business activities carried on by the trust. The governing test was whether the case fell within the limited categories contemplated by section 11(4A), namely a trust for public religious purposes carrying on the specified kind of business, or an institution wholly for charitable purposes where the business work was mainly carried on by the beneficiaries, with separate books maintained. The trust was neither a trust for public religious purposes nor an institution. Accordingly, the statutory conditions for exemption were not satisfied.

Conclusion: The assessee was not entitled to exemption under section 11 for the assessment years in question.

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