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d) The Tribunal below, however, turned down such objection of the Revenue of holding that to enable the trust to carry out its charitable object in effective manner if rental income was received by way of subletting, for that reason, the exemption could not have been denied by the Assessing Officer. It was further pointed out that in the past also, the assessee got the benefit of exemption in respect of the selfsame rental income and, therefore, there was no just reason for disallowing the relief claimed.

We have already pointed out that aforesaid finding has been reversed both by the Commissioner of Income-tax (Appeals) and the Tribunal and the Tribunal pointed out that to enable the trust to carry out its charitable object in effective manner if rental income was received by way of subletting, for that reason, the exemption could not have been denied by the Assessing Officer.

We, thus, find that there is no material which is available on record to justify the simple subletting done by the assessee in order to continue its charitable activity to be branded as a "business activity" and the Commissioner of Income-tax (Appeals) and the Tribunal below rightly did not bring the case within the purview of Section 11(4A) of the Act.