DHARMAPOSHANAM CO. KERALA vs COMMISSIONER OF INCOME TAX, KERALA

The Supreme Court held that the income from conducting kuries and money lending by the appellant company does not qualify for exemption under Section 11(1)(a) of the Income Tax Act, 1961. The Court clarified that business is considered 'property' under Section 11(1)(a) and that the definition of 'charitable purpose' under Section 2(15) excludes activities involving profit. The Court emphasized that if a trust's activities include profit-making without restrictions, it cannot be deemed charitable, thus upholding the decisions of the Income Tax Appellate Tribunal and the Kerala High Court.