a) The assessee-trust was formed with the main objective of alleviating human suffering, eradication of illiteracy, poverty and imparting of sound education with opportunities for research. It was running an Auditorium in the name of community hall which was given on rent for different commercial activities like marriage functions, exhibition, etc.
b) The assessee claimed that the income earned from auditorium was not a business income and should be exempted under section 11 because the same income was used for the charitable purpose of the trust.
c) The AO denied such claim of exemption under section 11. The CIT(Appeals) confirmed the additions made by the AO. Aggrieved-assessee filed the instant appeal.
The ITAT held as under: