person in receipt thereof--
.................
(c) in the case of a trust for charitable or religious
purposes or a charitable or religious institution,
any income thereof ... defines "charitable purpose". The last
portion thereof includes "advancement of any other object of
general public utility". It is accepted position
person is carrying on charitable activity, are no longer
relevant and apposite. Even if the profits earned are used for
charitable purposes, but fee, cess ... primary or dominant purpose of the trust or institution has
to be examined to determine whether the said trust/institution
was involved in carrying
High Court observed as under:-
"As noticed above, from the objects of the assessee, it is
conducting training centres and colleges for various courses ... observations made by the Supreme Court in Loka
Shikshana Trust 's case [1975] 101 ITR 234 (SC), for holding
that, the assessee
