https://www.taxtmi.com/caselaws?id=255729 The proviso to the definition of charitable purpose in Section 2(15) must be read down to avoid arbitrariness under Article 14: it excepts from charitable status only activities that are essentially trade, commerce or business, or services ancillary to them, where the dominant and prime objective is profit. If an institution's primary objective is profit-making, its objects cannot qualify as charitable; conversely, institutions not driven primarily by profit but advancing objects of general public utility retain charitable character. Applying this test, the impugned denial of approval under Section 10(23C)(iv) was set aside and approval was directed to be granted. en-us Thu, 22 Jan 2015 00:00:00 +0530 Fri, 06 Feb 2026 13:16:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255729 The proviso to the definition of charitable purpose in Section 2(15) must be read down to avoid arbitrariness under Article 14: it excepts from charitable status only activities that are essentially trade, commerce or business, or services ancillary to them, where the dominant and prime objective is profit. If an institution's primary objective is profit-making, its objects cannot qualify as charitable; conversely, institutions not driven primarily by profit but advancing objects of general public utility retain charitable character. Applying this test, the impugned denial of approval under Section 10(23C)(iv) was set aside and approval was directed to be granted. Case-Laws Income Tax Thu, 22 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255729