Charitable trust investments in trustee-interested partnership breached s.11(5), s.13 exclusion; exemption denied, income taxed at top rate.

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....Charitable trust investments in a partnership in which a trustee had a substantial interest were held to contravene the prescribed mode of investment requirement and to fall within the related-party exclusion, thereby attracting disqualification of exemption. The reasoning emphasised that the investment was not made in modes authorised for trusts and that the recipient qualified as a related party, invoking the statutory exclusion and nullifying the trust exemption; consequently the trusts income was treated as taxable at the maximum marginal rate and the assessing officers allowance was revised on that basis.....