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"It is no doubt true that the appellant-institute is not running any educational institution like a school or college. But that is not the only way of imparting instructions. It is not disputed that the appellant-institute gives scholarships to students studying in the School of Arts and Crafts, Madras, though it is done from the income derived from the Fund specially constituted for that purpose. It is also seen from the report published by the institute on the occasion of its seventy-fifth anniversary that the 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, method and finish, etc. Indeed it was for this purpose that the Institute approached the Government of Madras and obtained the grant of Rs. 20,000 in 1903. We are, therefore, inclined to accept the contention that the main object of the appellant-institute falls under the head 'Education'."

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.

31. The learned judges have held that the object of the trust was not "education" but "the advancement of any other object of general public utility ". In view of this decision, which has been affirmed by the decision in CIT v. Dharmodayam Co. and the fact that the assessee in the present case is not running any educational institution like a school or college, we are of the opinion that the object of the assessee is not "education". The activity of the assessee in granting scholarships to students studying in the School of Arts and Crafts, Madras, and sending its superintendent or other persons connected with the institute to various places where handicrafts articles are made by artisans for advising them on improving production methods and finish, etc., would fall only under the head "Advancement of any other object of general public utility". Regarding this aspect the Supreme Court has observed in the same decision, viz., Sole Trustee, Loka Shikshana Trust v. CIT thus (p. 242) :