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1990 (11) TMI 5

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..... e of handicrafts, without setting up educational institutions or training centres for advancement of studies would constitute charitable purpose and would, as such, qualify for exemption - - - - - Dated:- 16-11-1990 - R. M. SAHAI. and K. N. SAIKIA. ORDER This appeal by certificate is from the judgment and order of the Madras High Court in Tax Cases Nos. 383 of 1974 and 780-789 of 1976, r .....

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..... s linked or connected with an activity for profit and that the object of the assessee was not a "charitable purpose" within the meaning of section 2(15) of the Act. In arriving at the judgment the High Court mainly relied on a decision of this court in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 which has subsequently been explained by this court in CIT (Addl.) v. Surat Art Silk Cloth Man .....

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..... ords "not involving the carrying on of any activity for profit" qualify or govern only the last head of charitable purpose and not the earlier three heads. Where, therefore, the purpose of a 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 .....

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