Dy.Cit (E) -2(1) , Mumbai vs Mumbai Educational Trust, Mumbai on 30 September, 2022
• George Educational, Medical and Charitable
Society Vs. Asst. Director of Income Tax (2002)
80ITD 619 (Coch)
Charitable trust-Exemption under s. 11'-Bar of s.
13(1)(c)-Assessee-society using the residential house
of its chairman as a guest-house for accommodating
the chairman and governing council members
whenever they visited Madras and also other guests-
it was not used as exclusive residence of the
chairman after it was acquired on lease by the
assessee-Provisions of s. 13(1)(c) and s. 13(2) were
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ITA Nos. 1828 to 1831/Mum/2022
Mumbai Education Trust; A.Y. 08-09 to 11-12
not attracted- property in question was not made
available for the use of any person referred to in sub-
s (3) of s. 13, within the meaning of s. 13(2) even if
no rent or compensation was charged installation or
the governing council members, directly or indirectly-
equipments were not installed at the personal
residence of the specified persons-Assessee entitled
for exemption under s.11-AO was not justified in
adopting a segmented approach and allowing
exemption to income from activities in Kerala and
denying the exemption for the activities in Tamil
Nadu.