TMI Blog1976 (12) TMI 7X X X X Extracts X X X X X X X X Extracts X X X X ..... Income-tax Appellate Tribunal, Madras Bench, under s. 256(1) of the I.T. Act, 1961, has referred the following questions for the opinion of this court: " (1) Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that S. Rm. M. CT. M. Tiruppani Trust fulfills the condition laid down in section 88(5)(iii) for the assessment year 1967-68 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xpln. 3 to the entire section under which the expression charitable purpose " occuring in the section does not include any purpose, the whole or substantially the whole of which is of a religious nature. In this case, for the year 1967-68, the assessee had made a donation of Rs. 2,500 to the Tiruppani Trust and in the assessment year 1968-69, it had made a donation of Rs. 1,500. The question tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing pasumadam and nandavanam, etc., need not necessarily result in any benefit to any particular religious community. Mr. J. Jayaraman, the learned counsel for the revenue contends that this reasoning of the Tribunal, on the face of it, is erroneous because the repairing and renovation of old Hindu temples will be exclusively for the benefit of the Hindu community and consequently it is an exclusi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... all the objects for which the trust was created in view of the provisions contained in s. 80G(5)(iii) read with Expln. 3 thereto. In view of the failure on the part of the Tribunal to consider the entire trust deed it has become impossible for us to answer the questions referred to this court one way or the other. Therefore, leaving the Tribunal to go into the entire controversy again so far as i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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