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2004 (5) TMI 44 - DELHI HIGH COURTHeld that when a donor trust which is itself a charitable and religious trust donates its income to another trust, the provisions of section 11(1)(a) can be said to have been met by such donor trust and the donor trust can be said to have applied its income for religious and charitable purposes, notwithstanding the fact that the donation is subjected to any conditions - Whether the assessee-trust could be held to have lent the sum of Rs. 77,000 to the DCM Ltd. without adequate security within the meaning of section 13(2)(a) and hence the interest income of Rs. 5,200 wherefrom was rightly brought to tax by the Income-tax Officer?" - It may be relevant to note that so far as the adequacy of interest is concerned, the Revenue is not disputing the same – This question is purely on the facts and it cannot be said to be a question of law and, therefore, the question is not required to be answered
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