1975 (3) TMI 6

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....empt from tax subject to verification by the Appellate Assistant Commissioner of the facts with reference to the provisions of section 11(1)(a) of the Income-tax Act, 1961 ? " This reference relates to the assessment year 1965-66, the relevant previous year being the calendar year 1964. The controversy in this reference is whether the income derived by the assessee-association from the business of export of sugar and interest from current and fixed deposits is exempt from income-tax under section 11(1)(a) of the Act. It may be noted that the assessee made similar claim in the assessment years 1958-59 to 1961-62 under section 4(3)(i) of the Indian Income-tax Act, 1922. Regarding the assessee's claims in the aforesaid years the Supreme Cou....

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....ise, it will lead to a self-contradictory situation because the reason for including the object of general public utility as a charitable purpose was that it was not a charitable purpose with a blanket cover for any object of general public utility but with the severe limitation that the advancement of an object of general public utility would not involve the carrying on of any activity for profit or else it would not be a charitable purpose within the meaning of section 2(15) of the Income-tax Act, 1961. That, in our view, is the true import, meaning and significance of this new definition with the expression ' the advancement of any other object of general public utility not involving the carrying on of any activity for profit '. In other....