{"id":138051,"date":"1995-10-13T00:00:00","date_gmt":"1995-10-12T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/the-addl-commissioner-ofincome-vs-the-a-l-n-rao-charitable-trust-on-13-october-1995"},"modified":"2015-03-16T03:23:42","modified_gmt":"2015-03-15T21:53:42","slug":"the-addl-commissioner-ofincome-vs-the-a-l-n-rao-charitable-trust-on-13-october-1995","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/the-addl-commissioner-ofincome-vs-the-a-l-n-rao-charitable-trust-on-13-october-1995","title":{"rendered":"The Addl. Commissioner Ofincome … vs The A.L.N. Rao Charitable Trust on 13 October, 1995"},"content":{"rendered":"
Supreme Court of India<\/div>\n
The Addl. Commissioner Ofincome … vs The A.L.N. Rao Charitable Trust on 13 October, 1995<\/div>\n
Equivalent citations: 1996 AIR 344, \t\t 1995 SCC (6) 625<\/div>\n
Author: M S.B.<\/div>\n
Bench: Majmudar S.B. (J)<\/div>\n
           PETITIONER:\nTHE ADDL. COMMISSIONER OFINCOME TAX & ANR.\n\n\tVs.\n\nRESPONDENT:\nTHE A.L.N. RAO CHARITABLE TRUST\n\nDATE OF JUDGMENT13\/10\/1995\n\nBENCH:\nMAJMUDAR S.B. (J)\nBENCH:\nMAJMUDAR S.B. (J)\nJEEVAN REDDY, B.P. (J)\n\nCITATION:\n 1996 AIR  344\t\t  1995 SCC  (6) 625\n JT 1995 (7)   339\t  1995 SCALE  (5)742\n\n\nACT:\n\n\n\nHEADNOTE:\n\n\n\nJUDGMENT:\n<\/pre>\n
\t\t      J U D G M E N T
\nS.B. Majmudar, J.\n<\/p>\n
     This appeal  by special  leave is\tdirected against the
\ndecision of  the Division  Bench of the Karnataka High Court
\nin Writ Appeal No.864 of 1974 decided on 4th September 1975.
\nThe said  writ appeal,\tmoved on  behalf of  the Revenue  by
\nAdditional Commissioner\t of Income  Tax,  Mysore  and  First
\nIncome Tax  Officer, Mangalore Circle, Mangalore against the
\norder of  learned Single Judge Venkataramiah, J., as he then
\nwas, in\t the  Writ  Petition  No.597  of  1973\tcame  to  be
\ndismissed by the Appellate Bench of the High Court. In order
\nto highlight  the grievance  of the Revenue in this appeal a
\nfew relevant introductory facts are required to be noted.
\nBackground Facts\n<\/p>\n
—————-\n<\/p>\n
     Respondent A.L.N. Rao Charitable Trust, Mangalore, is a
\ncharitable trust.  For\tthe  assessment\t year  1969-70,\t the
\nrespondent,  hereinafter   referred  to\t as  “the  assessee”
\nsubmitted  its\tReturn\tto  the\t First\tIncome-Tax  Officer,
\nMangalore Circle.  In the  said Return, the assessee claimed
\nthat a\tsum of\tRs.85,262\/- which  was the surplus income of
\nthe  previous  year,  was  exempt  from\t tax  under  Section
\n11(1)(a) and  sub-section (2)  of the  said Section.  On the
\nAssessing Authority  holding that  the\tassessee  is  not  a
\ngenuine Trust  and  therefore  not  entitled  to  claim\t the
\nbenefit of  Section 11,\t the assessee  preferred  an  appeal
\nbefore\the   Appellate\tAssistant  Commissioner,  which\t was
\ndismissed. In  the second  appeal preferred  by the assessee
\nbefore the  Income Tax\tAppellate Tribunal, it was held that
\nthe assessee  was  a  charitable  trust\t and  therefore\t was
\nentitled to claim exemption from tax under Section 11 of the
\nIncome Tax Act, 1961 (hereinafter referred to as `the Act’).
\nIn I.T.R.C.  No.31 of 1973 which was a reference made at the
\ninstance of  the Department,  the High Court by its judgment
\ndated 4.8.1975\tanswered the  question referred in favour of
\nthe assessee  and  against  the\t Department.  That  judgment
\nbecame final.  Consequently there  remained no dispute about
\nthe eligibility\t of the assessee to claim benefit of Section\n<\/p>\n
11.
\n     The Assessing  Authority took up the assessment to pass
\nan order in accordance with the judgment of the Tribunal and
\nmade an\t order on  21.1.1972  by  which\t it  held  that\t the
\nassessee, after\t complying with\t the requirement  of  giving
\nnotice under  Section 11(2)  (a), had  invested 75%  of\t the
\naccumulated income  intended to\t be applied  for  charitable
\npurposes in  future years  as  required\t by  clause  (b)  of
\nSection 11(2)  and therefore,  the entire surplus income was
\nexempt from tax.\n<\/p>\n
     The Commissioner  of Income  Tax, on  looking into\t the
\norder dated  21.1.1972 passed by the Assessing Authority was
\nof the\tview that  the order  of the Assessing Authority was
\nerroneous as  he had  not applied  his mind  to the question
\nwhether the  assessee had  complied with  the provisions  of
\nSection 11(2)  and that\t if he\thad applied  his mind to the
\nsaid provisions, he would have noticed that the assessee had
\nnot invested  the entire  surplus income,  viz., Rs.85,262\/-
\n(but only  Rs.70,975\/-) and  therefore the  assessee was not
\nentitled to  the exemption  provided under Section 11 of the
\nAct. Thus,  in the opinion of the Commissioner, the order of
\nthe Income  Tax Officer\t was erroneous\tinasmuch as  it\t was
\nprejudicial to\tthe interests  of the  Revenue. He  issued a
\nshow-cause notice  under Section 263 of the Act on 18.1.1973
\nto the\tassessee to  show cause as to why the entire surplus
\nincome of  Rs.85,262\/- should  not be  brought to  tax.\t The
\nassessee, on receipt of the said notice, approached the High
\nCourt  for   relief  under  Articles  226  and\t227  of\t the
\nConstitution and  prayed for  the issue\t of a  Writ  in\t the
\nnature of  Certiorari to  quash the  Notice dated  18.1.1973
\nissued by  the Commissioner.  In that  writ  petition  (W.P.
\nNo.597 of  1973), Venkataramiah,  J. made an order directing
\nthe Commissioner  to dispose  of the  proceedings  initiated
\nunder Section  263 in  the light  of his  order\t as  to\t the
\ninterpretation of  Section 11(1)(a) and Section 11(2) of the
\nAct.\n<\/p>\n
     Before the\t learned Single Judge, the contention of the
\nDepartment was\tthat  in  order\t to  claim  exemption  under
\nSection 11,  the assessee  should have\tinvested the  entire
\nsurplus income\tin  one\t or  the  other\t of  the  securities
\nmentioned in  Section 11(2)(b)\tof the\tAct and\t it  is\t not
\nsufficient if  75% of  the surplus  income  alone  has\tbeen
\ninvested by  the  assessee.  The  learned  counsel  for\t the
\nassessee urged\tthat the  assessee  had\t complied  with\t the
\nrequirements  of   Section  11;\t according  to\tthe  learned
\ncounsel, the  assessee was entitled to exemption from tax in
\nrespect of  25% of  the accumulated  income  or\t Rs.10,000\/-
\nwhichever was  higher plus  that portion  of the accumulated
\nincome in  respect of  which the conditions prescribed under
\nClauses (a)  and (b)  of Section  11(2) had  been satisfied.
\nAccording to the assessee, since it had deposited 75% of the
\naccumulated income  in the  Securities mentioned  in Section
\n11(2) (b),  the entire\tsurplus income which had accumulated
\nwas not taxable.\n<\/p>\n
     The learned single Judge rejected the contention of the
\nRevenue and  upheld he\tcontention of  the assessee  in part
\nonly. The  learned Judge held that the assessee was entitled
\nto exemption  from tax only in respect of 75% of the surplus
\nincome which was accumulated for future use.\n<\/p>\n
     The Revenue  carried the  matter in  writ appeal  which
\ncame to\t be decided  by the  impugned judgment. The Division
\nBench on interpretation of Section 11(1) (a) and sub-section
\n(2) thereof  as they  stood at\tthe relevant  time, took the
\nview that 25% of the accumulated income of the Trust arising
\nin the\tprevious got  exempted from income tax under Section
\n11(1) (a).  That Section  11 (2) dealt with remaining 75% of
\nthe accumulated\t income of the previous year and if such 75%
\nof the\taccumulated income  was invested as laid down by the
\nsaid provision the Trust was entitled to get even the 75% of
\nthe accumulated\t income exempted  from income tax payable on
\nthe income  arising to\tthe Trust  in the  previous year. In
\nshort  while  dismissing  the  appeal  of  the\tRevenue\t the
\nDivision Bench\tof the\tHigh Court  on interpretation of the
\nSections  took\t a  view  which\t was  wholly  in  favour  of
\nrespondent-Trust. For  taking the  said\t view  the  Division
\nBench of  the High  Court referred  to similar view taken by
\nthe  High   Court  of\tJammu  &  Kashmir  in  the  case  of
\nCommissioner of\t Income Tax,  Patiala v.  Shri Krishen Chand
\nCharitable Trust<\/a> (1975) 98 ITR 387.\n<\/p>\n
Rival Contentions\n<\/p>\n
—————–\n<\/p>\n
     Learned counsel appearing for the appellants vehemently
\ncontended that\tthe interpretation  placed by Division Bench
\nof the\tHigh Court  on the  relevant provisions\t of  Section
\n11(1) (a)  and 11(2)  of the  Income Tax  Act, 1961  as they
\nstood at the relevant time is not well sustained. That it is
\ntrue that  under Section  11(1) (a)  25% of  the accumulated
\nincome of  the Trust  arising during  the previous  year  or
\nRs.10,000\/- whichever  was higher  was exempted\t from income
\ntax. But  as laid  down by  Section 11(2)  at the  stage  of
\ninvestment of such accumulated income unless cent percent of
\nsuch  accumulated  income  was\tinvested  as  per  the\tsaid
\nprovision the  assessee-Trust would  not be  entitled to the
\nbenefit of  exclusion of  such\taccumulated  income  of\t the
\nprevious year from the tax net of the Income Tax Act. It was
\nfurther conented  that the  subsequent of  Section 11(2)  as
\nbrought on  the Statute\t Book by  Taxation Laws\t (Amendment)
\nAct, 1975  clearly showed  a different legislative intention
\nand was\t not merely of a classificatory nature as assumed by
\nthe Division  Bench of\tthe High  Court. The learned counsel
\nfor the\t Revenue, however,  fairly submitted  that  the\t his
\nsubmission are\tbased on  the express language of Section 11
\n(1)(a) read  with Section  11(2) of the Act as applicable at
\nthe relevant  time and\the is  not supported by any decision
\nrendered by any of the High Courts on this point.\n<\/p>\n
     Learned counsel  for  the\trespondent-assessee  on\t the
\nother hand  submitted that  the view  taken by\tthe Division
\nBench of  the High  Court on  the interpretation  of Section
\n11(1) (a)  and Section\t11(2) of the Income Tax Act, 1961 as
\napplicable at  the relevant  time is  the only\tcorrect\t and
\nplausible view that the Division Bench of the High Court was
\njustified in  agreeing with  the view on similar lines which
\nappealed to  the Jammu\t& Kashmir High Court in Commissioner
\nof  Income  Tax\t v.  Shri  Krishen  Chand  Charitable  Trust<\/a>
\n(supra). He  also submitted that similar view has been taken
\nby the\tHigh Courts of Kerala, Madhaya Pradesh,Madras,Bombay
\nand Rajasthan in the following decisions:\n<\/p>\n
     1. Commissioner  of Income Tax, Kerala-I
\n     v. Shree  Padmanabhaswami\ttemple\tTrust
\n     (1979) 120 ITR 42 (Ker.);\n<\/p><\/blockquote>\n
     2. Commissioner of Income Tax, Kerala v.
\n     H.H.  Marthanda   Verma   Elayaraja   of
\n     Travancore Trust  and Others<\/a>  (1981) 129
\n     ITR 191 (Ker.);\n<\/p><\/blockquote>\n
     3. Mohanlal  Trust\t v.  Commissioner  of
\n     Income  Tax,   M.P.(1980)\t122  ITR  130
\n     (M.P.);\n<\/p><\/blockquote>\n
     4. Commissioner  of  Income  Tax,\tTamil
\n     Nadu-IV,\tMadras\t  v.   C.M.   Kothari
\n     Charitable\t Trust<\/a>\t(1984)\t149  ITR  573
\n     (Mad.);\n<\/p><\/blockquote>\n
     5.\t Commissioner\tof  Income   Tax   v.\n<\/p><\/blockquote>\n
     Trustees  of   Bhat  Family     Resaerch\n     Foundation (1990)\t185 ITR\t 532  (Bom.);\n     and\n<\/pre>\n
     6. Commissioner of Income Tax v. Anjuman
\n     Moinia  Fakharia\t(1994)\t208  ITR  568
\n     (Raj.).\n<\/p><\/blockquote>\n
Consideration of the Rival Conentions\n<\/p>\n
————————————-\n<\/p>\n
     Before we\tproceed to  deal with  the rival contentions
\ncentering round he true scope and ambit of Section 11(1) (a)
\nand Section  11(2) of the Income Tax Act, 1961 as applicable
\nto the assessment year in question, namely, 1969-70 it would
\nbe apposite  to refer  to these\t provisions at\tthe  outset.
\nThese provisions  as they stood at the relevant time read as
\nunder:\n<\/p>\n
     “11 (1).  Subject to  the provisions  of
\n     sections 60  to 63,  he following income
\n     shall  not\t be  included  in  the\ttotal
\n     income of\the previous year of he person
\n     in receipt of the income-\n<\/p><\/blockquote>\n
     (a) income\t derived from  property\t held
\n     under trust  wholly  for  charitable  or
\n     religious purposes,  to  the  extent  to
\n     which such\t income is  applied  to\t such
\n     purposes in  India and,,  where any such
\n     income is accumulated for application to
\n     such purposes in India, to the extent to
\n     which the\tincome so  accumulated is not
\n     in excess\tof 25% of the income from the
\n     property\tor   rupees   ten   thousand,
\n     whichever is higher, ….
\n     (2) Where\tthe persons  in recip  of the
\n     income have  complied with the following
\n     conditions, the restriction specified in
\n     clause (a)\t or clause  (b) of subsection
\n     (1) as  respects accumulation or setting
\n     apart shall  not apply  for  the  period
\n     during which  the said conditions remain
\n     complied with:-\n<\/p><\/blockquote>\n
     (a) such  persons\thave,  by  notice  in
\n     writing to\t the Income-tax Officer in he
\n     prescribed\t  manner,    specified\t  the
\n     purposes for  which the  income is being
\n     accumulated or  set apart and the period
\n     for  which\t  the\tincome\t is   to   be
\n     accumulated or set apart, which shall in
\n     no case exceed ten years;\n<\/p><\/blockquote>\n
     (b) The  money  so\t accumulated  or  set
\n     apart  is\tinvested  in  any  Government
\n     security as  defined in  clause  (2)  of
\n     section 12\t of the Public Debt Act, 1944
\n     (XVIII  OF\t  1944),  or   in  any\tother
\n     security which  may be  approved by  the
\n     Central Government in this behalf.”<\/p><\/blockquote>\n
     Section 11\t underwent an  amendment  by  Taxation\tLaws
\n(Amendment) Act,  1975. As  we are  not concerned with these
\namended provisions  in the  present case, we need not dilate
\non them.\n<\/p>\n
     A mere  look a  Section 11(1)  (a) as  it stood  at the
\nrelevant  time\tclearly\t shows\tthat  out  of  total  income
\naccruing to  a trust in the previous year from property held
\nby i  wholly for  charitable or\t religious purpose,  to\t the
\nextent the  is applied\tfor  such  religious  or  charitable
\npurpose, the  same will get out of the tax net but so far as
\nthe income  which is not so applied during the previous year
\nis concerned  at least\t25% of\tsuch income  or\t Rs.10,000\/-
\nwhichever is higher, will be permitted to be accumulated for
\ncharitable or  religious purpose  and will also get exempted
\nfrom the tax me. Then follows sub-section (2) which seeks to
\nlift the restriction or the ceiling imposed on such exempted
\naccumulated income  during the previous year and also brings
\nsuch further  accumulated income  out  of  tax\tnet  if\t the
\nconditions laid\t down by  sub-section (2)  of Section 11 are
\nfulfilled meaning  thereby the\tmoney so  accumulated is set
\napart to  be invested  in the  Government securities etc. as
\nlaid down  by clause  (b) of  sub-section 11  apart from the
\nprocedure laid\t down  by clause (a) of Section 11 (2) being
\nfollowed by  the assessee-trust. If Rs.1,00,000\/- are earned
\nas the\ttotal income  of he  previous year by the trust from
\nproperty held  by i  wholly  for  charitable  and  religious
\npurposes and if Rs. 20,000\/- are actually applied during the
\nprevious year  by the  said   trust to\tsuch  charitable  or
\nreligious purposes he income of Rs.20,000\/- will be exempted
\nfrom being  considered for  the purpose\t of income tax under
\npar of\tSection 11(1).\tSo far\tas the remaining Rs.80,000\/-
\nare concerned if they could not be actually applied for such
\nreligious or  charitable purposes  during the  previous year
\nthen as\t per Section  11(1) (a)\t at leas  25% of  such total
\nincome from property or Rs.10,000\/- whichever is higher will
\nalso earn  exemption from being considered as income for the
\npurpose of  income tax,\t hat is,  Rs.25,000\/- will  thus get
\nexcluded from  the extent  net. Thus out of the total income
\nof Rs.1,00,000\/-  which has  accrued to the rust Rs.25,000\/-
\nwill earn  exemption from  payment of income tax per Section
\n11(1)(a) second\t part. Then  follows sub-section  (2)  which
\nstates that  ceiling or\t the limit  or\tthe  restriction  of
\nincome to  the extent  of 25%  of the income or Rs.10,000\/-,
\nwhichever is  higher for  earning income  tax  exemption  as
\nengrafted under\t Section 11(1)\t(a) will  get lifted  if the
\nmoney so  accumulated is  invested as  laid down  by Section
\n11(2) (b)  meaning   thereby out  of the  total\t accumulated
\nincome of  Rs.80,000\/- accruing\t during\t previous  year\t and
\nwhich  could  not  be  spent  for  charitable  or  religious
\npurposes by  the Trust balance of Rs.55,000\/- if invested as
\nlaid by\t sub-section (2) of Section 11 will also be excluded
\nfrom the  tax net.  But for  such investment  and if Section
\n11(1) alone  had applied  Rs.55,000\/- being  he\t balance  of
\naccumulated income  would have\tbeen covered  by he tax net.
\nLearned\t counsel   for\tthe   Revenue  submitted   that\t the
\ninvestment as contemplated by sub-section (2) (b) of Section
\n11  must   be  investment   of\tall  accumulated  income  in
\nGovernment securities  etc., namely, 100% of the accumulated
\nincome and  not only  75% thereof.  And if  that is not then
\nonly the  invested accumulated\tincome to  the extent of 75%
\nwill get excluded from income tax assessment. But so far the
\nremaining 25% of the accumulated income in concerned it will
\nno earn\t such exemption.  It is difficult to appreciate this
\ncontention. The\t reason is  obvious. Section  11, subsection
\n(1) (a)\t operates on  its own. By its operation two types of
\nincome earned  by the trust during he previous year from its
\nproperties are\tgiven exemption from income tax, (i) the par
\nof the\tincome of  previous year which is actually spent for
\ncharitable or  religious purposes in that year; and (ii) out
\nof the\tunspent accumulated  income of the previous year 25%
\nof such\t total property\t income or  Rs.10,000\/- whichever is
\nhigher can  be permitted  to be\t accumulated by\t the  Trust,
\nremarked for  such charitable  or religious purposes. 25% of
\nthe income  Rs.10,000\/- whichever  is higher  will also\t get
\nexempted from  income tax.  That exhausts  he  operation  of
\nSection\t 11(1)\t(a).  Then  follows  sub-section  (2)  which
\nnaturally deals\t with the  question  of\t investment  of\t the
\nbalance of  accumulated income\twhich has  still not  earned
\nexemption under\t sub-section (1) (a). So far as that balance
\nof accumulated\tincome is  concerned ,\tthat also  cam\tearn
\nexemption from\tincome tax  meaning   thereby the ceiling or
\nthe limit  of exemption of accumulated income tax as imposed
\nby sub-section (1) (a) of Section 11 would get if additional
\naccumulated income  beyond 25%\tor Rs.10,000\/-\twhichever is
\nhigher, as he case may be, is invested as laid by Section 11
\n(2)  after   following\tthe  procedure\tlaid  down  therein.
\nTherefore, sub-section\t(2) only will have to operate qua he
\nbalance of  75% of  he total  of the previous year or income
\nbeyond Rs.10,000\/-  whichever is  higher which\thas butt not
\ngot the\t benefit of  tax exemption under sub-section (1) (a)
\nof Section  11. If  learned counsel for the Revenue is right
\nand if\t100% of\t the accumulated income of the previous year
\nis to  be invested  sub-section (2)  of Section\t 11  to\t get
\nexemption from\tincome\ttax  then  the\tceiling\t of  25%  or
\nRs.10,000\/- whichever  is higher,  which  is  available\t for
\naccumulation of\t income of  the previous year for the rust o
\nearn exemption from income tax as laid by Section 11 (1) (a)
\nwould be rendered redundant and the said exemption provision
\nwould become  otiose. It  has to  be kept in view the out of
\nthe accumulated\t income of  the previous  year an  amount of
\nRs.10,000\/- of\t25%  of\t the  total  income  from  property,
\nwhichever is  higher , is given exemption from income tax by
\nSection 11(1)  (a) itself.  That exemption is unfettered and
\nnot subject  to any  conditions. In  other words  it  is  an
\nabsolute  exemption.   If  subsection  (2)  is\tso  read  as
\nsuggested by the learned counsel for the Revenue, what is an
\nabsolute and  unfettered exemption  of accumulated income as
\nguaranteed by  Section 11(1)  (a) would\t become a restricted
\nexemption as  laid down by Section 11(2). Section 11(2) does
\nnot operate  to whittle\t down or  to cut across he exemption
\nprovisions contained  in Section  11(1) (a)  so far  as such
\naccumulated income of the previous year is concerned. It has
\nalso to\t be appreciated\t that sub-section  (2) of Section 11
\ndoes  not   contain  any   non\tobstacle   clause   like   ”
\nnotwithstanding\t the   provisions   of\t sub-section   (1)”.
\nConsequently it\t mus be held that Section 11(1) (a) has full
\nplay and if still accumulated income of the previous year is
\nleft to\t be dealt  with and  to\t be  consideration  for\t the
\npurpose\t  for the  income tax  exemption, sub-section (2) of
\nSection 11  can be  pressed in service and if it is complied
\nwith then  such additional  accumulated income beyond 25% or
\nRs.10,000\/-, whichever\tis higher,  can also  earn exemption
\nfrom income  on compliance which the conditions laid down by
\nsub-section (2)\t of Section  11. It is true that sub-section
\n(2) of\tSection 11  has not  clearly mentioned the extent of
\nthe accumulated\t income is to be invested. But on a conjoint
\nreading of he aforesaid two provisions of Sections 11(1) and
\n11(2) this  is the  only result which can follow. It is also
\nto be  kept in\tview the under the earlier Income Tax Act of
\n1922 exemption\twas available  to charitable  trusts without
\nany restriction\t upon the  accumulated income.\tThere was  a
\nchange in  this respect under the present Act of 1961. Under
\nthe present  Act, any income accumulated in excess of 25% or
\nRs.10,000\/- whichever  is higher,  is axable  under  Section
\n11(1) (a) of the Act, unless he special conditions regarding
\naccumulated as laid down in Section 11(2) are complied with.
\nIt is  clear, therefore,  that if the entire income received
\nby a  trust is\tspent for charitable purposes in India, then
\nit will\t not be\t taxable butt  if there is a saving, i.e. to
\nsay an\taccumulated  of\t 25%  or  Rs.10,000\/-  whichever  is
\nhigher, it  will not  be included  in  the  taxable  income.
\nSection 11(2)  quoted above further liberalizes and enlarges
\nthe exemption.\tA combined  reading of\tboth the  provisions
\nquoted above clearly show that Section 11(2) while enlarging
\nhe scope  of exemption\tremoves the  restriction imposed  by
\nSection 11(1)  (a) but\tit does\t not take  away he exemption
\nallowed by  Section 11(1)(a).  On the  express\tlanguage  of
\nSections 11(1)\tand (2) as they stood on the Statute Book at
\nthe relevant time no other view is possible.\n<\/p>\n
     In the light of the aforesaid discussion and keeping in
\nview the  illustration\twhich  we  have\t given\tearlier\t the
\ncombined operation  of Section 11(1)(a) and Section 11(2) as
\napplicable at  the relevant  time would\t yield the following
\nresult:\n<\/p>\n
     (i)  If the income derived from property
\n\t  held\t under\t trust\t wholly\t  for
\n\t  charitable or\t religious during the
\n\t  previous year\t is Rs.1,00,000\/- and
\n\t  if   Rs.20,000\/-    therefrom\t  are
\n\t  actually applied  to such  purposes
\n\t  in  India  then  those  Rs.20,000\/-
\n\t  will get  exempted from  payment of
\n\t  income tax  as per the firs part of
\n\t  Section 11(1)(a).\n<\/p><\/blockquote>\n
     (ii)  Out\tof the\tremaining accumulated
\n\t  income  of   Rs.80,000\/-  for\t  the
\n\t  previous year,  a  further  sum  of
\n\t  RS.25,000\/- will  get exempted from
\n\t  payment of income tax as per second
\n\t  part of  Section 11(1)(a). Thus out
\n\t  of the  total income\tderived\t from
\n\t  property   as\t   aforesaid   during
\n\t  previous     year,\t that\t  is,
\n\t  Rs.1,00,000\/-, Rs.45,000\/-  in  all
\n\t  will get  excluded from the tax net
\n\t  on a\tcombined operation  of\tfirst
\n\t  and\tsecond\t  part\t of   Section
\n\t  11(1)(a).\n<\/p><\/blockquote>\n
     (iii)The\t aforesaid     ceiling\t   of
\n\t  Rs.25,000\/- of  accumulated  income
\n\t  property of previous year, will get
\n\t  c under Section 11(2) to the extent
\n\t  the  balance\tof  such  accumulated
\n\t  income is  invested as laid down by
\n\t  Section    11(2).To\t  take\t   an
\n\t  illustration if, say, an additional
\n\t  amount of  Rs.20,000\/- out  of  the
\n\t  balance of  accumulated  income  of
\n\t  Rs.55,000\/-  is   invested  as  per
\n\t  Section 11(2)\t then this additional
\n\t  amount    of\t   Rs.20,000\/-\t   of
\n\t  accumulated\tincome\t  will\t  get
\n\t  excluded from\t he extent net as per
\n\t  Section 11(2).\n<\/p><\/blockquote>\n
     (iv) The  remaining   balance   of\t  the
\n\t  accumulated\t income\t    out\t   of
\n\t  RS.55,000\/-, that  is,  Rs.35,000\/-
\n\t  if not  invested as per sub-section
\n\t  (2) of  Section 11 will be added to
\n\t  he taxable  income of the trust and
\n\t  will\tnot  get  exempted  from  the
\n\t  extent net.\n<\/p><\/blockquote>\n
     (v)  If of\t the other  hand  the  entire
\n\t  remaining\t accumulated\t   of
\n\t  Rs.55,000\/- is  wholly invested  as
\n\t  per Section  11(2) the  said entire
\n\t  amount  of   Rs.55,000\/-  will  get
\n\t  exempted from the net.<\/p><\/blockquote>\n
     We may  also at  this stage  mention that\tHigh  Courts
\nKerala\tin   Commissioner  of  Income-Tax,  Kerala  v.\tH.H.
\nMathanda Varma\tElayaraja of  Travancore Trust & Ors.<\/a> [1981]
\n129 ITR\t 191; M.P.in  Mohanlal Hargovindas Public Charitable
\nTrust v. Commissioner of Income-Tax, m.p. [1980 122 ITR 130;
\nBombay in  Commissioner of  Income-Tax.\t Trustees  of  Bhatt
\nFamily Research Foundation [1990] 185 ITR 532; and Madras in
\nCommissioner of\t Income Tax,  Tamil Nadu-IV,  Madras v. C.M.
\nKothari Charitable  Trust<\/a> [1984]  149 ITR  573 have akin the
\nsame view  as Karnataka\t High Court  in the present case. We
\napprove the  view akin\tin the\taforesaid decisions. We also
\napprove the  similar view  taken by the Jammu & Kashmir High
\nCourt in  Shri Krishan\tChand Charitable  Trust (supra). The
\nlearned counsel\t for the Revenue, therefore, has made out no
\ncase for  our interference with the decision rendered by the
\nDivision Bench of Karnataka High Court.\n<\/p>\n
     In he  result ,  this appeal  fails and  is  dismissed.
\nHowever, in  the facts\tand circumstances  of the  case here
\nwill be no order as to costs.<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India The Addl. Commissioner Ofincome … vs The A.L.N. Rao Charitable Trust on 13 October, 1995 Equivalent citations: 1996 AIR 344, 1995 SCC (6) 625 Author: M S.B. Bench: Majmudar S.B. (J) PETITIONER: THE ADDL. COMMISSIONER OFINCOME TAX & ANR. Vs. RESPONDENT: THE A.L.N. RAO CHARITABLE TRUST DATE OF JUDGMENT13\/10\/1995 BENCH: MAJMUDAR […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-138051","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nThe Addl. Commissioner Ofincome ... vs The A.L.N. 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