Law:

Section:

Section 11, read with section 2(15), of Income-tax Act, 1961 - Charitable or religious trust - Exemption of income from property held under - Assessment year - 1962-63 - Whether although term education, as used in section 2(15) seems wider and more comprehensive than education through educational institutions, such as universities, whose income is given an exemption from income-tax separately under section 10(22) provided educational institution concerned does not exist for purposes of profit, yet educational effects of newspaper or publishing business are only indirect, problematical, and quite incidental so that, without imposing any condition or qualification upon nature of information to be disseminated or material to be published, mere publication of news or views cannot be said to serve a purely or even predominantly educational purpose in its ordinary and usual sense - Held yes - Appellant was sole trustee of a trust - Object of said trust was to supply people with organ of educated public opinion and to conduct journals in kannada and other languages for dissemination of useful news and information - Sole trustee had not only wide powers of utillsation of trust fund for proposes of trust but it could also divert its assets as well as any of funds of trusts to other institutions whose objects are similar to object of trust - There were no restrictions on trust earning profits in course of business and profit of trust apparently account for many gold increase in value of its assets - Whether income of trust was entitled to exemption under section 11, read with section 2(15) - Held, no. Words and phrases : Words 'education' and 'profit' as occurring in section 2(15) of the Income-tax Act, 1961. FACTS The appellant was the sole trustee of a trust. According to clause two of the trust deed the object of the trust were to educate the people of India in general and of Karnataka in particular by- (a)establishing, conducting and helping directly or indirectly institutions calculated to educate the people by spread of knowledge on all matters of general interest and welfare; (b)founding and running reading rooms and libraries and keeping and conducting printing…

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