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TMI Blog2009 (2) TMI 162X X X X Extracts X X X X X X X X Extracts X X X X ..... nd the activities of the trust are in conformity with the aims and objects of the trust. It has been registered with the Charity Commissioner, Government of Rajasthan – Held that - sole purpose of the trust was to run a dharamshala which is an object of general public utility and so when this was the sole object, the income derived therefrom in the shape of the rent from the dharamshala is exempt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessment years 1973-74, 1974-75 and 1975-76 declared that the trust run by the assessee is a charitable trust and its income is exempt under section 11 of the Income-tax Act, 1961. The Income-tax Officer did not accept the claim of the assessee. On appeal before the Appellate Assistant Commissioner of Income-tax, he reversed the order of the Income-tax Officer and permitted the benefit of s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... parties. The reference has been answered by this court in the case titled CIT v. Paramhans Ashram Trust [1993] 203 ITR 711. Dealing with the same issue, the Division Bench of this court held as under (page 713): "In order to appreciate the arguments of learned counsel for the Revenue, it has to be seen as to whether the trust is a private trust or a public charitable trust. Normally, in a p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se of the words 'object of general public utility' can be interpreted to cover such trust where the intention is to give the benefit to sizable numbers of the public in contrast to an individual or group of individuals. The expenses in constructing new dharamshalas were considered as advancement of the charitable object of the trust which was held entitled to exemption under section 11 of the said ..... X X X X Extracts X X X X X X X X Extracts X X X X
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