General public utility requires benefits open to the general public; sectional benefits exclude charitable income exemption.

The text addresses the scope of the charitable exemption for income from property, clarifying that the proviso's phrase "general public utility" requires benefits be available to the general public rather than to a particular section; where association resolutions direct application of income to matters serving commercial interests or a defined class, that income does not qualify as derived from property held wholly for charitable purposes and therefore falls outside the exemption for income from charitable property.

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Issues: Whether interest income of the Grain Merchants' Association falls within the exemption in Section 4(3) of the Income-tax Act, 1922, as an income derived from property held for charitable purposes including objects of general public utility.

Analysis: Section 4(3) exempts income derived from property held under trust or other legal obligation wholly for religious or charitable purposes; the proviso states that "charitable purpose" includes relief to the poor, education, medical relief, and the advancement of any other object of general public utility. The relevant inquiry is the meaning of "general public utility" in the proviso. The expression denotes objects of public utility that are available to the general public as distinct from benefits confined to a particular section of the public. The association's resolution to apply the income to works of public utility was directed to matters serving those interested in commerce, thus conferring benefits limited to a section rather than the general public.

Conclusion: Issue answered against the assessees; the interest income is not exempt under Section 4(3) of the Income-tax Act, 1922.

Ratio Decidendi: An object of "general public utility" for the purposes of the exemption in Section 4(3) of the Income-tax Act, 1922, must confer benefits available to the general public and not advantages confined to a particular section of the public.

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