1. This is a reference at the instance of the Commissioner of Income-tax and the Income-tax Appellate

Tribunal, Cochin Bench has referred the following question to this Court.

"Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was justified in law in holding that the income of the assessee Is exempt from tax under S.11 of the Income-tax Act, 1961?"

2. The assessee is the Cochin Chamber of Commerce and Industry, Cochin, and the years of assessments are 1964-65,1965-66 and 1966-67. The memorandum of association of the Chamber contained clauses very similar, if not identical, to those of the Indian Chamber of Commerce whose case we considered in the decision in Commissioner of Income-tax, Kerala v. Indian Chamber of Commerce (1971) 80 I. T. R.645. For activities similar to that carried on by the Indian Chamber of Commerce, namely the issuance of certificates for survey and weighment. the assessee bad received amounts in the accounting periods relating to the three assessment years referred to earlier, of Rs. 1,16,167/-, Rs. 1,12,919/-and Rs. 1,22,786/-respectively. The net income of the assessee for these three years came to only Rs. 7893, Rs.