The following table sets out in columns 3 & 4 the net annual value of the property less the statutory deductions permissible under section 9 of the Income tax Act, 1922 and the net excess of expenditure over the income of the assessee (other than the rental income) incurred in connection with all its activities for the assessment years relating to which dispute arises in this group of appeals Previous year Assessment Amount Net excess (calendar year) year Rs. Rs. (1) (2) (3) (4) 1947 1948 49 3,400 7,431 1948 1949 50 6,154 7,139 1949 1950 51 6,928 5,266 1950 1951 52 5,740 10,173 1952 1953 54 8,072 13,672 1953 1954 55 8,072 17,397 In proceedings for assessment before the Second Additional Income tax Officer, City Circle 1, Madras, it was contended that Sup./65 11 568 the annual value of the building was not assessable in its hands as the assessee was a charitable institution within the meaning of section 4(3) (i) of the Income tax Act, 1922.