Section 11 exemption upheld where prior year ruling applied and no distinguishing facts were shown.

Registration under section 12A supported exemption under section 11, and the proviso to section 2(15) did not displace that relief on the facts recorded. The matter was treated as covered by earlier decisions in the assessee's own case, including the jurisdictional High Court's view that no substantial question of law arose. As no distinguishing material was shown and the present facts were found pari materia with the earlier year, the exemption claim was upheld and the disallowance was deleted.

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Issues: Whether the assessee was entitled to exemption under section 11 of the Income-tax Act, 1961, notwithstanding the proviso to section 2(15).

Analysis: The assessee was registered under section 12A of the Income-tax Act, 1961. The issue was treated as covered by earlier decisions in the assessee's own case, including the decision of the jurisdictional High Court, which had upheld the Tribunal's view and held that no substantial question of law arose. No distinguishing material was shown to depart from that view, and the present facts were found to be pari materia with the earlier year considered by the High Court.

Conclusion: The assessee was held entitled to exemption under section 11, and the Revenue's challenge to the deletion of the disallowance failed.

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