General public utility requires benefit to the public generally, not a restricted commercial class, for charitable exemption.

Income from investments was not exempt under Section 4(3) of the Indian Income-tax Act, 1922, because the association's property was not held under trust or legal obligation wholly for charitable purposes. The Bombay High Court held that "general public utility" requires an object beneficial to the public generally, not one confined to a limited section such as persons interested in commerce. As the association's objects served only that restricted class, the claim to charitable exemption failed and the Revenue's position prevailed.

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Issues: Whether the assessee association's income from investments was exempt under Section 4(3) of the Indian Income-tax Act, 1922, on the footing that it was held under trust or legal obligation for a charitable purpose, namely the advancement of any other object of general public utility.

Analysis: The exemption was confined to income derived from property held under trust or other legal obligation wholly for religious or charitable purposes. The expression "general public utility" was treated as referring to an object of public utility available to the general public, and not to a utility confined to a section of the public. The association's objects were directed to the benefit of works of public utility for persons interested in commerce, which constituted only a limited section of the public.

Conclusion: The assessee did not fall within the exemption under Section 4(3) of the Indian Income-tax Act, 1922, and the answer was against the assessee and in favour of the Revenue.

Ratio Decidendi: An object is not "general public utility" unless it serves the public generally and not merely a section of the public.

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