Conclusion- The CIT(A) noted that the law required the AO to bring on record cogent evidence to justify the invocation of Section 13 of the IT Act to deny exemption, and the material collected from the internet cannot be termed as corroborative piece of evidence. Thus HLI is a business held under charitable trust and HNF is a special purpose vehicle set up for the sole purpose of effectuating the charitable intent of HLI. 13(1)(a)]b. charitable trust created or established on or after 1­4-1962 for the benefit of any particular religious community or caste [Sec. Popular products/formulation of the respondent/assessee Trust are Rooh-Afza, Rogan Badam-Shrin, Cinkara, Safi & Chavyan Prash etc. The CIT(A) noted that the law required the AO to bring on record cogent evidence to justify the invocation of Section 13 of the IT Act to deny exemption, and the material collected from the internet cannot be termed as corroborative piece of evidence.