Charitable purpose test for societies turns on dominant objects, with ancillary powers not defeating exemption eligibility.

A society's charitable character is determined by reading its memorandum as a whole to identify its dominant objects, not by isolating ancillary clauses. Where the main objects relate to education, medical relief, and objects of general public utility, provisions relied on by the revenue may be treated as enabling powers to carry out those primary purposes. On that approach, the amendment did not alter the society's essential character, and the ancillary clauses did not defeat exemption eligibility under section 4(3)(i) of the Indian Income-tax Act, 1922. The result was that the assessee was regarded as established for charitable purposes and entitled to exemption.

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Issues: Whether the assessee-society was established for charitable purposes and was entitled to exemption under section 4(3)(i) of the Indian Income-tax Act, 1922.

Analysis: The memorandum of association had to be read as a whole to ascertain the real objects of the society. The provisions relied on by the revenue, when read in context, were treated as powers intended to carry out the primary charitable objects rather than independent non-charitable objects. The main objects in the memorandum were found to relate to education, medical relief, and objects of general public utility, and the amendment did not materially alter that position. The distinction between objects and enabling powers was applied, and the ancillary clauses were held not to defeat the charitable character of the trust.

Conclusion: The assessee-society was held to be established for a charitable purpose and entitled to exemption under section 4(3)(i) of the Indian Income-tax Act, 1922.

Final Conclusion: The question referred was answered in favour of the assessee, and the claim for exemption succeeded.

Ratio Decidendi: Where the dominant objects of a society are charitable, ancillary clauses conferring powers to carry out those objects do not deprive the institution of its charitable character for exemption purposes.

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