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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the assessee's activity of advancing loans to poor women in villages fell within the first limb of the definition of charitable purpose as relief of the poor under Section 2(15) of the Income-tax Act, 1961, or within the fourth limb as advancement of any other object of general public utility.
Analysis: The activity found from the record was advancing loans to poor women in villages. That activity was treated as directly answering the description of relief to the poor, which is a distinct charitable limb under Section 2(15). Once the activity was so characterised, it could not be treated as falling within the residual limb of general public utility for the purpose of disqualifying it.
Conclusion: The assessee's activity was held to fall within relief of the poor under the first limb of Section 2(15), and the Revenue's challenge failed.
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