1984 (8) TMI 38

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....come-tax Appellate Tribunal, Cochin Bench, has, pursuant to the judgment of this Court in 0. P. No. 1960 of 1977, referred to us the following question : " Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal is Tight in law in holding that the income of the assessee for the assessment year 1971-72 is exempt from tax under section 11 of the Income-tax Ac....

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....lege Hostel for women, the staff hostel attached to the Sree Narayana College for women; (b) to complete the work of establishing a technological institution at Quilon and a college at Sivagiri; (c) to establish and maintain other institutions intended for the educational, cultural, economic, social and religious welfare and advancement and for the physical well being of the people; (d) t....

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.... trust or institution is relief of the poor, education or medical relief, the requirement of the definition of 'charitable purpose' would be fully satisfied, even if an activity for profit is carried on in the course of the actual carrying out of the primary purpose of the trust or institution." We do not see anything in clauses (c) and (d) which is inconsistent with " charitable purpose " as d....

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....ties. Clause (d) authorising the trust to accept any other trust thus refers to an object which is purely charitable in scope. Promotion of material and spiritual well being of backward people is indeed a charitable purpose. In the circumstances, we do not agree that either the word " physical " or " material " takes it out of charitable purpose. Both the AAC and the Tribunal have correctly, in ou....