Court : Madhya Pradesh
Decided on : May-21-1982
Reported in : (1982)30CTR(MP)139; [1983]140ITR795(MP)
G.P. Singh, C.J. 1. This is a reference made by the Income-tax Appellate Tribunal referring for our answer the following questions of law : '(1) Whether, on the material on record and especially the deed of trust on being read as a whole together with the accounts of the trust, the legal inference drawn by the Tribunal, that the applicant was not entitled to exemption from tax under Section 11 of the Income-tax Act, 1961, was correct (2) Whether, on the material on record, could it be legally inferred that mere letting out of house property involved the carrying on of any activity for profit ?' 2. The relevant assessment years are 1967-68 to 1971-72. The assessee is a trust. The assessee claims that it is a charitable trust entitled to exemption under Section 11 of the I.T. Act, 1961. This claim of the assessee has been negatived on the ground that the assessee is not a trust for a charitable purpose as defined in Section 2(15) of the Act. 3. The assessee trust was constituted by a tr...
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