2000 (12) TMI 60

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....C.J.--At the instance of the Revenue, the Income-tax Appellate Tribunal, Delhi Bench-E (in short "the Tribunal"), has referred the following question, under section 256(1) of the Income-tax Act, 1961 (in short "the Act"), for the opinion of this court: "Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the business of the Jugnu activity ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....all Mahila Shilp Vidyalaya transferred all its assets and liabilities to the foundation on the condition that it shall apply the assets for the object of Lala Madan Mohan Lall Mahila Shilp Vidyalaya Society, In furtherance of the objects of that society, for the purpose of which assets were placed on trust with the foundation, it was running a vocational training centre in the name of "Jugnu" whic....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tility and it did not involve the carrying on of any activity for 'profit. The Tribunal accepted this stand holding, inter alia, as under: "On the materials placed before us there is no scope for concluding that the primary object or dominant purpose of the institution is the carrying on of an activity for profit. The real purpose of the institution is the advancement of the object of imparting....