COMMISSIONER OF INCOME TAX Vs. GEETHA BHAVAN TRUST

JUDGEMENT

(1.) The assessee is a trust constituted by a deed dated 1-9-1977. The objects of the Trust are to provide for: -

(2.) Having heard both sides we do not find any reason to direct reference of any questions of law as arising out of the order" of the Tribunal.

(3.) Counsel for the revenue contends that while it is true that the income sought to be assessed was derived from the educational institutions during the year in question, the objects of the trust were wide and therefore it could not be said that the trust as such existed only for educational purposes. It was also contended that since a surplus had been generated from the running of the schools the institution must be treated as one run for profit We find it difficult to agree with either of these submissions.