Law:

Section:

JUDGMENT Varadarajan, J.-The identical questions referred by the Income-tax Appellate Tribunal, "A" Bench, Madras, for the opinion of this court in these two cases are the following: T.C. No. 182 of 1974. "Whether, on a proper construction of the trust deed dated June 4, 1962, the Tribunal was right in holding that the objects of the trust are not (for) charitable purposes within the meaning of the said expression as denned in section 2(15) of the Income-tax Act, 1961, and that consequently its income for the assessment years 1964-65 and 1965-66 is not exempt from tax under section 11 of the Income-tax Act, 1961 ? " T.C. No. 252 of 1974. "Whether, on a proper construction of the trust deed dated June 4, 1962, the Tribunal was right in holding that the objects of the trust are not (for) charitable purposes within the meaning of the said expression as defined in section 2(15) of the Income-tax Act, 1961, and that consequently its income for the assessment year 1966-67 is not exempt from tax under section 11 of the Income-tax Act, 1961 ? " The assessee is the same in both the cases. The questions relate to the assessment years 1964-65 to 1966-67. The objects of the trust, according to the trust deed dated June 4, 1962, are: (a)To establish, maintain, run, develop, improve, extend, grant donations for and to aid and assist in the establishment, maintenance, running, development, improvement and extension of elementary schools, secondary schools, high schools, colleges, universities, workshops, weaving, industrial, technological and other art, craft and science institutes, schools and institutions of Tamil or Sanskrit learning, hostels for the benefit of students and generally all kinds of educational institutions, whether general, technical, vocational, professional or of other description whatsoever for the welfare and uplift of the general Indian public and to institute and award scholarships in India for study, research, apprenticeship for all or any of the said purposes. (b)To establish, maintain, run, develop, improve, extend, grant donations for and to aid and assist in the establishment, maintenance, running, development, improvement and extension of…

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