Loan Between Charitable Trusts Does Not Violate Income Tax Act; Section 11 Exemption Upheld, Sections 13(1)(d) & 11(5) Explained.

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....Exemption u/s 11 - advancing a loan to another charitable trust - nothing has been brought on record to establish that the common trustees have substantial interest in the other trust - the amount advanced cannot be held to be in violation of Sec.13(1)(d) - Sec.11(5) cannot be applied to present facts as the money advanced is not an investment but a loan - Exemption cannot be denied - AT....