Charitable expenditure on founder biography accepted where the trust's object and past treatment remained unchanged.

Expenditure incurred for preparing and publishing a founder's biography was treated as part of a charitable trust's principal objects, where the institution had long been recognised as charitable and the same spending had been accepted in earlier assessment years. The Court found no change in law or in the nature of the activity and held that it was not proper to reopen the settled issue. No reference was called for on whether the expenditure was charitable and entitled to exemption, and the application was rejected.

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Issues: Whether a reference should be directed on the question whether the expenditure incurred for preparing and publishing the biography of a founder was charitable and entitled to exemption.

Analysis: The institution had long been recognised as charitable and approved, and the same expenditure for the same project had been accepted in earlier assessment years. The expenditure was incurred in furtherance of one of the principal objects of the trust, namely preparation and publication of biographical and research studies. In these circumstances, the Court held that it was not proper to reopen the same issue when there had been no change in law or in the nature of the activity.

Conclusion: No reference was called for and the application was rejected.

Ratio Decidendi: Where a charitable institution has consistently been accepted as such and incurs expenditure in furtherance of its principal charitable objects, the expenditure is charitable and a reference on that settled question need not be directed in the absence of any change in law or facts.

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