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1. These are references by the Income-tax Appellate Tribunal, Cochin Bench, under Section 256(1) of the I.T. Act, 1961, sent up at the instance of the revenue. The two references arise out of an appeal filed to the Tribunal by the revenue and a cross-objection preferred to it by the assessee. Both related to the assessment year 1971-72. The assessee, Shree Padmanabhaswami Temple Trust, Trivandrum, is a charitable and religious trust. The previous year is the year ended March 31, 1971. The controversy revolves round the question whether the trust whose objects are admittedly charitable within the meaning of Section 2(15) of the Act, was entitled to the exemption conferred by Section 11 of the I.T. Act, as it stood at the relevant time. The material part of the section as it stood at the relevant time read as follows :