Charitable purpose definition clarified: profit-making activity to advance objects does not automatically negate charitable status. The qualification 'not involving the carrying on of activity for profit' in the definition of charitable purpose under section 2(15) applies to the object of general public utility and not to its advancement; trusts conducting profit-making activities to advance charitable objects therefore retain charitable status, while only objects that themselves involve carrying on activities for profit disqualify charity status. The board withdraws its prior instruction and permits completion of pending assessments in accordance with this interpretation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Charitable purpose definition clarified: profit-making activity to advance objects does not automatically negate charitable status.
The qualification "not involving the carrying on of activity for profit" in the definition of charitable purpose under section 2(15) applies to the object of general public utility and not to its advancement; trusts conducting profit-making activities to advance charitable objects therefore retain charitable status, while only objects that themselves involve carrying on activities for profit disqualify charity status. The board withdraws its prior instruction and permits completion of pending assessments in accordance with this interpretation.
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