TaxTMI 
TaxTMI 
1992 (11) TMI 31
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....d that its objects constitute a charitable purpose as defined in section 2(15) of the Income-tax Act, 1961 ? 2. Whether the Appellate Tribunal is correct in not applying the decision of the Supreme Court in the case of Yogiraj Charity Trust v. CIT [1976] 103 ITR 777, even though the assessee is a mixed trust existing for not only for charitable purposes but also for non-charitable and non religious purposes and clause 4(j) of the memorandum of association gives wide discretion to carry out any of the objects to the exclusion of all other objects and the assessee can pursue only objects at 4(a) and 4(i) ? 3. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is correct in law in holding that the predomin....
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....self-help and mutual help of women and children. (e) To undertake welfare activities for the promotion of moral, educational and physical improvement. (f) To organise training facilities to improve the efficiency of the trainees. (g) To purchase, construct and alter buildings and maintain them suitably for the purpose of the association. (h) To encourage co-operative movement. (i) To obtain contracts from the Government, public bodies or others and get them executed with the help of the employees. (j) To do all things as are incidental or conducive to the attainment of any or all the above objects, The association has been registered under section 12A of the Income-tax Act, 1961 (for short, "the Act'), by the Commission....
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....ded for payment by Hindusthan Machine Tools for services rendered by the association of a sum of Re. 1 per watch for casing assembly and Rs. 4.50 per watch for complete assembly of watch from the components. For setting up the assembly unit, the assessee received a grant of Rs. 1 lakh from the Central Social Welfare Board, New Delhi, and further grants of Rs. 18,750 and Rs. 16,350 under the socio-economic programme of the Central Social-Welfare Board in 1975 and 1976. For setting up its ancillary unit, two 'A' type sheds were allotted by the Karnataka State Small Industries Corporation in the Peenya Industrial Estate in 1977. In that year, it employed 52 women drawn up from the weaker sections of the society, who were given vocational train....
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....tivity of advancement must not involve profit-making activity. The word 'involving' in the restrictive clause is not without significance. An activity is involved in the advancement of an object when it is enwrapped or enveloped in the activity of advancement. In another case, it may be interwoven into the, activity of advancement, so that the resulting activity has a dual nature or is twin-faceted. Since we are concerned with the definition of 'charitable purpose', and the definition defines in its entirety a 'purpose' only, it will be more appropriate to speak of the purpose of profit-making being enwrapped or enveloped in the purpose of the advancement of an object of general public utility or, in the other kind of case, the purpose of p....