Charitable trust income from marriage hall letting treated as property income and exempt under section 11.

Income from letting out a marriage hall by a charitable trust was treated as property income, not business income, because the letting was undertaken to further the trust's charitable objects rather than as an independent business activity. On that basis, the restriction under section 13(1)(bb) did not apply, and the receipts remained eligible for exemption under section 11 of the Income-tax Act, 1961.

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Issues: Whether income derived from letting out a marriage hall by a charitable trust is business income or property income, and whether such income is exempt under section 11 of the Income-tax Act, 1961.

Analysis: The trust's objects were medical relief to the poor and spread of education. Letting out the Kalyana Mandapam was not an independent business object but an activity undertaken to further the trust's objects. The receipts were treated as income from property and not business income, so the restriction under section 13(1)(bb) did not apply.

Conclusion: The income from letting out the marriage hall was exempt under section 11 of the Income-tax Act, 1961, and the answer to the reference was in favour of the assessee.

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