General public utility and incidental profit-making can preserve charitable status where the dominant purpose remains non-profit.

An object qualifies as charitable under section 2(15) of the Income-tax Act, 1961 where its predominant purpose is charitable and any profit element is merely incidental; the profit-making restriction applies only when earning profit is the dominant purpose of the activity. Applying that principle, the Chamber's main object was to promote trade and commerce, which fell within advancement of an object of general public utility. Because profit-making was not its predominant purpose, its income remained exempt under section 11(1).

---

---

Issues: Whether the assessee's objects fell within the expression "advancement of any other object of general public utility" under section 2(15) of the Income-tax Act, 1961, and whether the activity carried on involved profit-making so as to deny charitable status and exemption under section 11(1).

Analysis: The Court applied the settled principle that an object remains charitable if its predominant purpose is charitable and any profit-making activity is merely incidental. It reiterated that the restriction in section 2(15) is attracted only where the predominant object and purpose of the activity is to earn profit. On the facts, the Chamber's dominant object was to promote trade and commerce, which is an object of general public utility, and profit-making was not its predominant purpose.

Conclusion: The assessee's objects were held to be charitable within section 2(15) of the Income-tax Act, 1961, and its income was held exempt under section 11(1); the appeal was dismissed.

---