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Ahmedabad Rana Caste Association vs Commissioner Of Income Tax, Gujarat on 16 September, 1971

8.4.9 The Ld. AR's reliance in the case of Ahmedabad Rana Caste Association v. CIT 82 ITR 704 (SC) is also of no help since the facts of both the cases are distinguishable. In the above cited case, the assessee was an Association of Persons belonging to Rana caste/community of the city of Ahmedabad providing education, medical help to the members of their community who are natives of Ahmedabad and other members of the community accepted by their caste according to its age old custom and usage and resident of the city. It was held in this case that to serve a charitable purpose it is not necessary that the objects should be to benefit ITA No.301 & 302/B/09 Page 16 of 17 the whole of mankind or all persons in a country or state, but it is sufficient if the intention is to benefit a section of the public. 8.4.10 While as in the present case (Bangalore Urban and Rural District Co-operative Milk Producers Societies Members and Employees Welfare Trust) is a trust formed for the upliftment and prosperity of the members of the milk producers societies and their family members and in order to safeguard the interest of the members of such societies. Therefore it goes without saying that the assessee trust emerges out from the members involved in a particular commercial activity and exists mainly for the purpose of the well being of the members of a particular trade/occupation on a mutuality concept.
Supreme Court of India Cites 7 - Cited by 86 - A N Grover - Full Document

Commissioner Of Income Tax vs Red Rose School on 7 February, 2007

8.4. With due respects, we have perused the finding of the Jurisdictional Hon'ble High Court referred supra on which the assessee has placed a strong reliance. The prime issue before the Hon'ble Court was that, whether the Hon'ble Tribunal was right to opine that, notwithstanding the various discrepancies and misapplication of the funds of the trust as noticed by the Commissioner, the trust nevertheless having the object of running educational institutions, would qualify as a trust having a charitable purpose as one of its objects and after referring to the various authorities on the subject, following the decision of Allahabad High Court in the case of CIT v. Red Rose School reported in (2007) 212 CTR (All) 394 and which in turn had followed several other like decisions of other High Courts, allowed the appeal being of the view that the scrutiny as to the application of funds is an exercise required to be undertaken by the assessing officer and not necessarily by the Commissioner while granting registration under section 12A in an application filed under section 12AA and accordingly allowed the appeal..... ."
Allahabad High Court Cites 13 - Cited by 122 - P Kant - Full Document
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