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Statutory housing board functions directed at housing development and general public utility can retain charitable status despite receipts that resemble commercial activity. Charges collected while discharging statutory public functions do not, merely because of their commercial character, trigger the exclusion for trade, commerce or business under section 2(15) read with section 13(8). The housing board therefore remained eligible for income-tax exemption under sections 11 and 12, and the Revenue's challenge to that exemption failed.
Statutory housing board functions directed at housing development and general public utility can retain charitable status despite receipts that resemble commercial activity. Charges collected while discharging statutory public functions do not, merely because of their commercial character, trigger the exclusion for trade, commerce or business under section 2(15) read with section 13(8). The housing board therefore remained eligible for income-tax exemption under sections 11 and 12, and the Revenue's challenge to that exemption failed.
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