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Trust Denied Tax Exemption u/s 11 Due to Mutuality Principle, Educational Objective Not Affected by Section 2(15) Proviso.

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....Exemption u/s 11 - claim denied relying on Principle of mutuality - quite clearly the object of the appellant trust is to promote education in the field of science of medicine and the profit on sale of books/journals is incidental thereto. In this view of the matter, proviso to Section 2(15) will have no application in the present case. It may be borne in mind that proviso to Section 2(15) comes into play only in respect of “any other object of general utility” and not in respect of relief to poor, education, medical relief etc. - AT....