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    <title>1967 (7) TMI 52 -  GUJARAT High Court</title>
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    <description>Income derived from property held under legal obligation was not exempt under section 4(3)(i) because the charitable-purpose test required a benefit to the community or a section of the community with a genuine public element. The beneficiaries were confined to a closed and indeterminate class within the Rana caste in Ahmedabad, including natives of Ahmedabad and persons admitted by caste usage, so they were not a section of the public. The class lacked a single impersonal characteristic and its admission-based nature destroyed public character, leaving the assessee ineligible for exemption.</description>
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    <pubDate>Tue, 25 Jul 1967 00:00:00 +0530</pubDate>
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      <description>Income derived from property held under legal obligation was not exempt under section 4(3)(i) because the charitable-purpose test required a benefit to the community or a section of the community with a genuine public element. The beneficiaries were confined to a closed and indeterminate class within the Rana caste in Ahmedabad, including natives of Ahmedabad and persons admitted by caste usage, so they were not a section of the public. The class lacked a single impersonal characteristic and its admission-based nature destroyed public character, leaving the assessee ineligible for exemption.</description>
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      <pubDate>Tue, 25 Jul 1967 00:00:00 +0530</pubDate>
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