YOGIRAJ CHARITY TRUST vs COMMISSIONER OF INCOME-TAX, NEW DELHI

The Supreme Court interpreted Section 4(3)(i) of the Indian Income-tax Act, 1922, clarifying that for a trust's income to qualify for exemption as charitable, it must benefit the public and not be solely for private religious purposes. The Court upheld the Delhi High Court's ruling that the income of the trusts in question, which was spent on religious and charitable purposes, did not meet the criteria for exemption under Section 4(3)(i). Consequently, all six references from the Income-tax Appellate Tribunal were answered negatively in favor of the Revenue.