Held that  the Assessing Officer has  accepted in the remand report that no loan was taken by the assessee-trust during the relevant year and no property of the trust has been utilized for the advantage of the trustees.. Therefore  it cannot be held that the assessee has violated the provisions of S.  36A the BPT Act. CIT(A) was justified in allowing the exemption.  Held that the amounts deposits in the bank accounts of the assessee trust were the contribution made by the members of the trust for its self help activities which has been confirmed by the contributors, and the AO having verified all the entries in the books of accounts relating to the bank accounts, the addition under s. 69A is not sustainable; assessee having given the details of self-help loans given to its members which are returnable without interest, addition under S 69B is also not sustainable.

Held that the trust was not created for the benefit of any particular religious community and that its membership was open to public at large irrespective of any caste etc., provisions of s. 13(1)(b) are not attracted. Held that the activity of the assessee-trust providing self-help loans without charging interest to its trustee on the same terms and conditions as it was given to any other member of the society is not hit by the provisions of S.  13(1)(c) read with  13.(2)  exemption under S. 11 cannot be denied. (AY. 2012-13)