1981 (4) TMI 10

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....d by PATHAK J.-These appeals by certificate granted by the High Court of Gujarat are directed against the judgment of the High Court delivered on June 29/30, 1972, on the application of s. 4(3)(i) of the Indian I.T. Act, 1922, and s. 11 of the I.T. Act, 1961. The assessment years involved are 1960-61, 1961-62 and 1962-63 (the corresponding accounting periods being the financial years ending ....

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....tion for the opinion of the High Court : " Whether, on the facts and in the circumstances of the case, the income of the assessee-trust is exempt under s. 4(3)(i) of the Indian I.T. Act, 1922, and s. 11 of the I.T. Act, 1961 ?" Before the High Court the controversy centred around sub-cls. (4) and (5) of cl. 3 of the memorandum of association of the respondent-association as well as sub-cl. (4) ....