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Dispute concerned denial of charitable exemption on grounds that properties were purchased in trustees' names triggering alleged violation of the private-benefit prohibition; contemporaneous documentary evidence including a registered rectification deed, encumbrance certificates and mutations established that the trust held possession, enjoyed the property, ran the school, and received fees, and trustees derived no personal benefit. On these facts the private-benefit prohibition did not apply and the trust's use of the property for its charitable objects sustained the exemption, with prior acceptance of assets by the revenue also noted as relevant to the outcome.
Dispute concerned denial of charitable exemption on grounds that properties were purchased in trustees' names triggering alleged violation of the private-benefit prohibition; contemporaneous documentary evidence including a registered rectification deed, encumbrance certificates and mutations established that the trust held possession, enjoyed the property, ran the school, and received fees, and trustees derived no personal benefit. On these facts the private-benefit prohibition did not apply and the trust's use of the property for its charitable objects sustained the exemption, with prior acceptance of assets by the revenue also noted as relevant to the outcome.
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