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(e) Giving grants-in-aid to managers and teachers and technical schools, classes or workshops and giving scholarships, grant or prizes to pupils of the same.
(f) Buying and selling or selling on commission articles produced by handicraftsmen or otherwise.
(g) (i) Purchasing, taking on lease or in exchange, hiring or otherwise acquiring any immovable or movable property and any rights or privileges that the Council may think necessary for the purposes of the Institute and in particular any land, buildings, machinery, easements and plant.
4.

Sri T. Madhava RaoScholarship Fund | | | These funds are utilised for the grant of scholarship to deserving students nominated by the Principal, School of Arts and Crafts, Madras.

5. Prince of Wales Scholarship Fund

6. C.W.E. Prize Fund.--This fund is meant for awarding a prize to the best student from the School of Arts and Crafts, Madras.

7. Government Travelling Fund.--This fund has been created with a sum of Rs. 20,000 granted by the Government of Madras for making tours to centres of arts and crafts to make personal contacts with a view to educate craftsmen in the matter of better finish and production of new articles required for meeting the market demands.

15. The other activity of the assessee is buying and selling or selling on commission, articles produced by handicraftsmen or otherwise and doing all such other lawful things as are incidental or conducive to the attainment of the aforesaid objects or any of them. In the memorandum and articles of association these and some other items of activities are mentioned as the means of carrying out the objects of the institute, extracted on page 2 of this judgment, (see supra pp. 360-361.)

16. The facts found by the Tribunal are that the assessee is not running any educational institution like a school or a college. The assessee is giving scholarships to students studying in the School of Arts and Crafts, Madras, but this is done out of two separate funds earmarked for the purpose, namely, Sri T. Madhava Rao's Scholarship Fund and the Prince of Wales Scholarship Fund. The assessee's superintendent and other persons connected with the institute go to various places where handicrafts articles are made by artisans and advise them on improving production methods, better finish, etc. This also is done out of the grant of Rs. 20,000 made by the Government of Madras in 1903 for making tours to centres of arts and crafts for making personal contacts with a view to educate craftsmen in the matter of better finish and production of new articles for meeting the market demands.

24. Two things have to be noticed so far as this decision is concerned. The first is that the business itself has been found to be held under a trust for religious or charitable purpose, namely, promotion of charity, education and industry, while in the present case, the business carried on by the assessee in buying and selling or selling on commission articles produced by handicraftsmen or otherwise itself has not been held under the trust for any religious or charitable purpose; but the alleged educational activities by way of granting scholarships and prizes and spending monies on tours to centres of arts and crafts for making personal contacts with a view to educate craftsmen in the matter of better finish and production of new articles required for meeting the market demands, are done with the monies separately provided for, namely, Sri T. Madhava Rao's Scholarship Fund and Prince of Wales Scholarship Fund from which scholarships are granted, and the money given by the Government of Madras in 1903 for making tours to centres of arts and crafts for the purpose mentioned above. The second thing to be noted is that the decision of the Division Bench of the Kerala High Court was taken by the revenue in appeal to the Supreme Court but the appeal was withdrawn, with the result that the decision of the Division Bench became final.