Advancement of general public utility exempts chamber property income where trade promotion serves a public section, not private gain.

Income from a chamber's immovable property was treated as exempt where the chamber's objects were directed to promoting and regulating trade and commerce, removing friction among merchants, framing commercial rules, arbitrating disputes, and disseminating commercial knowledge. Those activities were held to serve a sufficiently defined section of the public engaged in the relevant trade, not private members alone, so they fell within advancement of an object of general public utility. The absence of private gain and the obligation to apply income solely to the chamber's objects supported charitable character, and the property income was therefore exempt from tax.

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Issues: Whether the income derived from the assessee chamber's immovable property was exempt from tax as income from property held under a trust or legal obligation for charitable purposes.

Analysis: The objects clause showed that the chamber was constituted to promote and regulate trade and commerce in specified commodities, to remove friction between merchants, to frame rules for commercial dealings, to arbitrate disputes, to disseminate commercial knowledge, and to take other measures conducive to the proper conduct of trade. Such objects were held to benefit not merely individual members but a sufficiently defined section of the public, namely persons engaged in the relevant trade and commerce, and thus fell within the concept of advancement of an object of general public utility. The absence of private gain, the obligation to apply income solely towards the chamber's objects during its subsistence, and the line of authority treating promotion of trade and commerce as charitable where public benefit is present supported exemption under the relevant provisions.

Conclusion: The property income was exempt from tax and the answer was in favour of the assessee.

Ratio Decidendi: Promotion and protection of trade and commerce, when directed to the benefit of a section of the public and not to private gain, is advancement of an object of general public utility and is charitable for income-tax exemption purposes.

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