https://www.taxtmi.com/caselaws?id=38393 A trust deed that empowers trustees to apply income, and even corpus with unanimous consent, to both charitable and non-charitable objects does not satisfy the requirement that property be held wholly for charitable purposes. The court treated the assessee as bound by its concession that two objects were non-charitable and rejected the argument that those objects were merely subsidiary, because they were independent objects capable of direct application of trust funds. The preamble could not override the operative clauses of the deed. Exemption under section 4(3)(i) of the Indian Income-tax Act, 1922 was therefore unavailable. en-us Tue, 01 Jan 1974 00:00:00 +0530 Tue, 06 Apr 2010 10:13:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38393 A trust deed that empowers trustees to apply income, and even corpus with unanimous consent, to both charitable and non-charitable objects does not satisfy the requirement that property be held wholly for charitable purposes. The court treated the assessee as bound by its concession that two objects were non-charitable and rejected the argument that those objects were merely subsidiary, because they were independent objects capable of direct application of trust funds. The preamble could not override the operative clauses of the deed. Exemption under section 4(3)(i) of the Indian Income-tax Act, 1922 was therefore unavailable. Case-Laws Income Tax Tue, 01 Jan 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38393