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5. Before we deal with the question referred, it is necessary to dispose of some of the grounds urged by the learned counsel for the Commissioner. Sri G. R. Ethirajalu Naidu, the learned counsel appearing for the Commissioner, urged that the first deed, dated 15th July, 1935, creating the National Literature Publication Trust was irrevocable and, therefore, the trust deed, dated 10th of April, 1947, was void and if the trust deed, dated July 15, 1935, is looked into, it will be seen that the object of the trust was not a charitable purpose but political and since this aspect of the matter has not been considered by the statutory authorities, we should call for a supplementary statement of the case from the Tribunal in exercise of our power under section 258 of the Act. Another ground he urged was that the conduct of a newspaper as such is not an object of general public utility and the question has to be decided on the facts of each case.

6. There are limitations on the powers of this court under section 258 of the Act. The High Court cannot send back the case to the Tribunal to find out fresh facts and embark on a fresh line of enquiry or to take additional evidence. Before the Appellate Assistant Commissioner, the department did not contend that the objects of the trust are of a political nature. The Appellate Assistant Commissioner in paragraph 32 of his order states that it was not disputed that the objects of the trust are not of a political nature. Before the Tribunal also, the departments did not contend that the objects of the trust are of a political nature. No contention was raised that the trust deed, dated April 10, 1947, was void and that the objects of the trust have to be gathered from the earlier trust deed, dated July 15, 1935. The Income-tax Officer, the Appellate Assistant Commissioner and the Tribunal have all proceeded on the basis that the trust in question was created by the deed, dated April 10, 1947. Since our jurisdiction is advisory and that jurisdiction is confined to the question of law referred, it is not open to us to call for further information on the question whether the trust deed, dated April 10, 1947, was void. In regard to the second ground urged by Sri Naidu, the Income-tax Officer and the appellate authority have all proceeded on the basis that the object of the trust was a charitable purpose under the Indian Income-tax Act, 1922, and it is solely by reason of the addition of the clause "not involving the carrying on of any activity for profit" in section 2(15) of the Act, that the income of the trust is not exempt as it has ceased to be a trust for a charitable purpose under the new definition. It was not the case of the department at any stage that the object of the trust was not supplying the Kannada speaking people with an organ of educated public opinion and that the object of the newspaper conducted by the trust was political. In that view, we cannot, in exercise of our powers under section 258 of the Act, call for a supplementary statement of the case and to embark on a fresh line of enquiry.