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7. S.R.O. No. 1727 of 1993, issued under the KGST Act, came into force with effect from January 1, 1994 and the amendment thereof vide S.R.O. No. 427 of 1995 came into force with effect from April 1, 1995. Similarly S.R.O. No. 1731 of 1993, issued under the CST Act came into force with effect from January 1, 1994 and the amendment thereof vide S.R.O. No. 506 of 1995 came into force with effect from April 21, 1995. The benefit of S.R.O. No. 342 of 1963 is made available to sales by any charitable trust or charitable institution profit of which is solely utilised for charitable purposes. S.R.O. No. 1727 of 1993 confers benefit of exemption from sales tax on the sale of goods manufactured within the State by any charitable trust or charitable institution, if the profit earned is utilised solely for charitable purposes during the year or set apart to be utilised for charitable purposes. In case the profit so set apart for utilisation for charitable purpose is utilised for any purpose other than charitable, the institution shall disentitle itself for exemption under the notification during such year. By the amendment brought vide S.R.O. No. 427 of 1995, with effect from April 1, 1995 the exemption so granted is explained. Goods so manufactured by charitable trust or charitable institution get exemption in cases where such manufacturing is incidental to the main objective of such trust which shall be predominantly charitable. The claim by the petitioner of benefit of S.R.O. No. 1727 of 1993 is limited however to the period up to July 29, 1996 as with effect from that date the benefit is limited by insertion of a condition vide S.R.O. No. 584 of 1996 to the effect that the benefit shall be available only on condition that the annual turnover of the institution does not exceed Rs. 10 lakhs. The petitioner's turnover during all these years exceeds Rs. 10 lakhs. Similarly, vide S.R.O. No. 105 of 1967, issued under the CST Act, exemption is granted on sales turnover of such goods in the course of inter-State trade or commerce, provided the profits of such sales are solely utilised for charitable purposes. Vide S.R.O. No. 1731 of 1993 exemption to tax under the CST Act is granted to goods manufactured within the State by charitable institution the profit of which is solely utilised for charitable purposes with the further condition that where the profit so set apart for utilisation for charitable purpose is utilised for any purpose other than charitable, the institution shall disentitle itself for the exemption during such year. The exemption so granted was however limited by amendment vide S.R.O. No. 506 of 1995 with effect from April 21, 1995 to goods so manufactured, only in the event of such manufacturing being incidental to the main objective of such institution, which shall be predominantly charitable. Vide S.R.O. No. 987 of 1976 exemption is made in respect of tax payable under the KGST Act by pharmacies in regard to their turnover relating to purchase of goods which are subject to tax at the point of last purchase in the State subject to the condition that the goods so purchased are used by the pharmacies in the manufacture or preparation of goods for sale by them.

21. We are of the view that Schedule VII of S.R.O. No. 1727 of 1993, as modified by S.R.O. No. 427 of 1995 and Schedule IV of S.R.O. No. 1731 of 1993, as amended by S.R.O. No. 506 of 1995, do not have materially altered the position as far as the present assessee is concerned. In respect of sale of goods manufactured within the State by any charitable trust or charitable institution, the profit is entitled to exemption, if the profit, if any, is solely utilised for charitable purpose during the year or set apart to be utilised for charitable purpose. The "charitable purpose" is defined in wide terms. The amendment to Schedule VII, in serial number 5, in column (2), was substitution of the words "by any Charitable Trust or Charitable Institution" by the words "by any Charitable Trust or Charitable Institution where such manufacturing is incidental to the main objective of such institution which shall be predominantly charitable". Manufacturing of medicines, as far as the petitioner-assessee is concerned, cannot but be termed otherwise than as incidental to the main objective of the institution. The will refers to the manufacture as one of the areas where the Trust is to engage. The propounder has foreseen that sustenance of the organisation cannot be guaranteed, other than by continuous generation of income. The existence of the establishment, the objectives of the trust and the usefulness to the community is closely linked to the production of medicine and we need not comprehend the word "incidental" used in the amended notification so as to disjoint the basic purpose or consider the activity as one which is alien from being part and parcel of the main objective. The objective of the amendment itself was to ensure the nexus as between the two and there is no case for the Revenue that the trust as such was not predominantly charitable in nature or that the trust had any other objective which was not essentially charitable. The income derived by manufacture of medicine by the very nature of the activity would have had no comparison with the other limbs, but by accepting the interpretation of the Revenue, it may lead to absurd inferences, viz., that manufacture was the predominant activity. There is nothing illogical for an incidental activity to become the money spinning programme and for that reason alone, it will be unsafe to jump to weird conclusion.