Dismissing the appeal of the revenue the Court held that  the assessee was constituted under the Gujarat Maritime Board Act, 1981 and was engaged in the activity of administering, controlling and managing minor ports in the State of Gujarat is held to be  entitle to exemption in respect of fees collected  for attainment of the main object for the development of minor ports in the State of Gujarat and were not taxable is held to be not taxable . Relied on

CIT v. Gujarat Industrial Development Corporation [2017] 83 taxmann.com 366 (Guj) and Ahmedabad Urban Development Authority v. ACIT (E ) [2017] 396 ITR 323 (Guj)  (HC )  . Court also held that the  the income of a trust was required to be computed under section 11 on commercial principles after providing for allowance for normal depreciation and deduction thereof from the gross income of the trust.  and contribution to pension fund is held to be allowable ad deduction  ( AY.2009-10 to 2013-14 )