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5.3 We have seen the deed of Charitable Trust and found that the objects of the Trust which are prescribed under clause 4 almost all the objects are in the nature of charitable. The clause 4 of the trust deed is as under:
"OBJECTS OF THE TRUST: The trustees shall stand possessed of the Trust Fund and properties including the movable and immovable properties of the Trust for the following Charitable objects and purposes to the intent that the same shall be applied to charitable purposes in India or accumulated for application to such purposes in India to any member of public without any restrictions as to any particular religion, community, caste or creed and in all respects as the Trustees in their absolute discretion may think fit, that is to say:
13. To prepare scheme for the residence of the needy people of the society and to give guidance and relief to the needy for their residence needs."

5.4 On the basis of these sub clauses of clause 4, the ld Director of Income Tax (Exemption) has held that the objects of the assessee are vague in nature. In our view, the totality of all the sub. Clauses of clause 4 of Charitable Trust have to be taken into consideration. If the totality of these objects is taken into consideration then it is seen that the objects of the assessee are charitable in nature. In all other clauses, except clause 11, 12 & 13, the objects of the Trust provides that they are charitable in nature. For example, in clause 1 to 4, it is provided that Trust will provide medical relief and help to the poor and deserving persons by providing monetary and/or non-monetary held, and/or to open, form, establish, promote, set up, run, acquire, maintain, assist, finance, support running Hospitals, Nursing Home, Nature Cure Centre, Yoga Centre, Medication Centre etc. To provide for the educational grant, or scholarship, stipends, prizes, rewards, allowances and other financial and/or non-financial assistance in cash or kind to students and/or to open, form, establish, promote, set up run, acquire families, maintain, assist, finance, support in running school, colleges, boarding house, and Chatralaya. To provide livelihood and up-liftment of the children, girls, women men and needy. To pay or contribute partly or full any premium of medical insurance scheme for the medical need of people of the society and needy family.

5.8 The ratio of the decision in the case of Gangabai Charitie (supra) goes in favour of the assessee. The Supreme Court in this case has held as under:

"Affirming the decision of the High Court that it was not possible to cull out in clear terms any specific charitable or religious object from the trust deed to conclude that the trust was set up wholly for religious or charitable purposes. The "religious, charitable, cultural and social" purposes referred to in the deed were not avowed as the objects of the trust; they were only the objects of those who wished to put the trust property to use. There was no mention in the deed as to how the income derived from the trust property was to be utilised. There was no mandate that the income was to be spent on religious or charitable purposes. Therefore, the trust deed did not meet the requirements of sec. 11(1) (a) and the income of the trust was not exempt from tax.

11 In the present case also the objects of the Trust are such by which it is clearly established that objects of the assessee are charitable in nature and not for the purpose of profit attributable to the trusted for their own benefits. The clauses of the objects in the present case are for buying the property or construct the dwelling units for the purpose of allotting the same to the needy and weaker section of the society. If by any reason any profit arises out of the activities of the trust than that profit has to be utilised only for the purpose of charitable and not for the purpose of the trustee for their own benefit. Even in the clause 5 of application of income is provided in detail and how and why the funds are to be utilised and no trustee can get any benefit to the funds and income of the trust is to be utilised for the objects of the Trust which are charitable in nature. Therefore, no profit motive is found in the objects of the trust. It is also a matter of fact that the Assistant Commissioner of Charity, Grater Mumbai has granted certificate of Charity to the assessee, copy of which is placed at page 13 of the paper book. Therefore, for this reason, no doubt remains that the assesse's objects are charitably in nature. In view of these facts and circumstances, we direct the ld Director Income Tax (Exemption) to grant registration to the assessee in view of provisions of sec. 12A r.w.s 12AA of the Act. We order accordingly.