respondent is a trust registered under Bombay Public Trusts Act . Earlier it was known as Rajneesh Foundation. However, after amendment in the trust deed ... amendment in 1989. The relevant asst. yr. 1991-92 is of the period after the said amendment. If on the basis of said trust deed
trustees to hold property in the trust for the benefit of public at large, the
trust by its amendment clause in the trust deed ... correspondence between the
appellant trust and the revenue, trust deed in Kannada along with English
translation, supplementary trust deed dated 22.4.2002, certificate
noticed that the assessee had carried out amendment to the Trust
Deed without prior approval of the department. For the above
reasons ... trust were
excessive and unreasonable.
12. With regard to the amendment of trust deed, the DIT(E) was of
the view that the assessee ought
question that next arises is whether, on the terms of the amendment trust deed, the assessed is entitled to exemption under ... trust deed had been retrospectively amended would not save the trust from the denial of exemption. In other words, despite the amendment made
matter of the trust were utilised therein, such business was property held under trust under the trust deed. Before the amendment of the trust deed ... trust and after such profits were made good to the trust, such profits would be treated as trust estate or property held under trust
that the newspaper business is held in trust by the petitioner; that the trust is an irrevocable trust which has as its objects relief ... that provision, even after the amendment as the amendment has not excluded the business held in trust from the purview of Sections
examine the issue whether inclusion of any new
objects by an amendment to trust-deed is to be construed as an
illegality which would disentitle ... trust,
instead of that trust has been doing other activities. As observed
earlier, activities performed or objects of the assessee-trust are
concerned, they
days from the
date of amendment. This amendment has come in to effect from 1/04/2018. The
above amendment has been explained ... provisions in the Income Tax Act, 1961 that mandates
the trust to inform amendment to the objects, if the registration has already been
granted. Therefore
objectives of the trust is for charitable
purpose. No where in the objectives of the trust, it is
mentioned that the trust was carrying ... material
on record discloses that the proposed amendment of trust is
also duly registered and it is awaiting the approval from the
Director of Income
trust is very restricted and guided by the clauses of the trust
deed. This goes against the very sprit of the charitable trust ... that the assessee trust was constituted by the trust deed dated 02-12-
1993 and 13-04-1994 the assessee trust was granted the first
