Private family trust classification defeats section 11 exemption where trusteeship and income use remain family-bound.

A trust created for permanent management of family properties was treated as a private family trust, not a public religious trust, because the deed and scheme confined trusteeship to family members, described the temples and school as belonging to the Kovilakam, and limited income from the acquired school property to the temples. Public access to the temples and participation in festivals did not change the trust's character. On that basis, the trust was found not to be established for the public at large, and exemption under section 11 of the Income-tax Act, 1961 was unavailable.

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Issues: Whether the trust was a private family trust and not a public religious trust so as to deny exemption under section 11 of the Income-tax Act, 1961.

Analysis: The trust deed and scheme showed that the temples and the school were described as belonging to the Kovilakam, the trustees and their representatives were restricted to members of the family, and the income from the acquired school property was to be used only for the temples. The public being allowed to enter the temples or participate in festivals did not alter the character of the trust. On the terms of the award and scheme, the trust was created for permanent management of family properties and was not established for the public at large.

Conclusion: The trust was held to be a private family trust and not a public religious trust, and exemption under section 11 was not available.

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