COMMISSIONER OF INCOME TAX Vs. SRI GUJARATHI MANDAL

JUDGEMENT

(1.) THE following common question of law has been referred to us at the instance of the revenue relating to the assessee's assessment for the assessment years 1976 -77 and 1979 -80:

(2.) THE revenue contends that a trust set up to promote Gujarati languages is to be regarded as one set up to promote the interest of particular, religion or caste attracting the bar of Sec. 13(l)(b) of the Income tax Act, 1961 ('the Act') and, therefore, the trust is not entitled to the benefit of the exemption under Ss. 11 and 12 of the Act.

(3.) THE respondent, assessee, is Gujarathi Mandal, Salem. its object has been set out in its Memorandum of Association of Shri Gujarati Mandal, Salem, as follows: