Charitable-purpose exemption protects incidental rental income where trust property supports education, medical relief, or poverty relief objectives.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Charitable exemption remains available to trusts pursuing education, medical relief or relief of the poor where rental income and licence fees arise from property held under trust. The restrictive proviso to the charitable-purpose definition applies only to advancement of general public utility, not to specified charitable objects merely because incidental income is generated. A valid charitable registration cannot be disregarded without cogent material that activities are non-genuine or outside the charitable objects. Rental and licence receipts do not constitute commercial activity absent an independent business venture, private diversion of funds or departure from charitable purposes; exemption was consequently restored.....