The High Court held that the words derived from or some other similar words do not occur in section 10(22) of the Income-tax Act, 1961 , that, therefore, the word income as occurring in section 10(22) cannot be given a restrictive meaning and must be given its natural meaning or the meaning ascribed to it in section 2(24) , and that hence, an assessee who is entitled to exemption under section 10(22) can claim the benefit thereof for the purpose of income deemed to be chargeable to tax under section 68 . On appeal   Supreme Court  dismissed the appeal on the ground of low tax effect, keeping the question of law open.( AY. 1987-88, 1998-99)