Charitable trust status depends on trust deed objects; exemption under income-tax provisions remains a separate enquiry.

The trust deed's objects to establish and support hospitals, nursing homes and orphanages, and to grant relief during natural calamities were treated as charitable in nature. The trust's status had to be determined from those objects, not from the separate question of income exemption. Compliance with sections 11, 12 and 13 of the Income-tax Act, 1961 was identified as a distinct matter and was not examined in the appeal. The trust was therefore to be recorded as a charitable trust, and the assessment was to be amended accordingly.

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Issues: Whether the assessee trust was a public charitable trust and entitled to have its status recorded accordingly.

Analysis: The objects set out in the trust deed were to establish, maintain and grant aid to hospitals, nursing homes and orphanages, and to grant relief during natural calamities. These objects were held to be charitable in nature. The question whether the income of the trust was exempt under section 11 of the Income-tax Act, 1961 depended upon compliance with the conditions in sections 11, 12 and 13, which was a separate matter and was not examined in the appeal. The status of the trust, however, had to be determined from the objects of the trust deed.

Conclusion: The assessee was held to be a charitable trust and the assessment was to be amended by recording that status.

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