Allowing the appeal the Tribunal held  that the issue of applicability of section 11(4A) was already decided by the jurisdictional High Court in the assessee’s own case in favour of the assessee. When the Department itself had expressed its inability to verify the documents, as directed to it by the Tribunal, either on account of voluminousness of the documents or for any other reason whatsoever, the assessee’s contention that, being a charitable trust, its income was taxable under sections 11, 12 and 13 and, therefore, section 145 was not applicable, could not be rebutted by the Revenue. Hence, the assessee could not be kept in abeyance from getting justice which it deserved.  High Court’s remanding of the matter regarding the assessee’s entitlement to exemption under section 11, which was denied on account of change in accounting practice, was also decided in favour of the assessee. (AY. 1985-86, 1989-90, 1993-94)