Court : Income Tax Appellate Tribunal ITAT Patna
Reported in : (1993)45ITD101(Pat.)
..... not apply to charitable trusts and religious trusts and, therefore, the trusts falling in section 11(4) were outside the scope of section 13(1)(bb) of the act because, otherwise, the purpose of granting exemption to charitable trusts will be frustrated. (iii) marginal note/heading of section 11 was indicative of the intention of the ..... its character of a charitable purpose merely because some profit arose from the activity. the definition of charitable purpose as given in section 2(15) of the income-tax act is as under : " 'charitable purpose' includes relief of the poor, education, medical relief, and the advancement of any other object of general public utility not ..... their lordships of the supreme court no doubt mainly dealt with the amendment of the definition of charitable purpose given in section 2(15) of the income-tax act and held that, where the object of the trust was of " general public utility" and the predominant object of the activity was to carry out charitable purposes .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Patna
Reported in : (1998)64ITD129(Pat.)
..... not include "loss" and peculiar results would follow if income was clubbed with loss everywhere. our attention was invited to s. 167a of the act, inserted by the finance act, 1992, w.e.f. 1st april, 1993, according to which, in case of a firm which is assessable as a firm, tax shall be charged on its total income at the maximum ..... legal objection should be rejected.replying to the above submissions, the learned counsel for the assessee submitted that the supreme court had held in cit vs. g. r. karthikeyan (1993) 201 itr 866 (sc) that the meaning of "income" should be the same as that of the word occurring in legislative list. the meaning was of the widest amplitude ..... there should not be any intendment or "ifs 'and' buts" while interpreting those provisions particularly in a fiscal statute like the it act. the latest judgment of the bombay high court in the case of cit vs. p. m. shah (1993) 203 itr 792 (bom) and that of the madras high court in the case of tmt.thangalakshmi vs. ito (1994) .....
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