Dismissing the appeal of the revenue the Court held that , denial of exemption under S.13(1)(d)(iii) of the Act is to be restricted to only income earned from shares to be taxed at marginal rate under S.164(2) and not entire income of assessee.
CIT( E) v. Santokba Durlabhji Trust Fund ( 2018) 93 taxmann.com 324 ( Raj)(HC) Editorail: SLP is garnted to the revenue , CIT( E) v. Santokba Durlabhji Trust Fund ( 2018) 93 taxmann.com 325 (SC)
S. 13 : Denial of exemption-Trust or institution- Investment restrictions -Shares received by way of gift failed to dispose off or convert said shares in to permissible investments – Denial of exemption is to be restricted to only income earned from shares to be taxed at marginal rate under S.164(2) and not on entire income of the assessee.[ S. 11,13(1)(d) (iii),164(2) ]