GANGABAI CHARITIES vs COMMISSIONER OF INCOME-TAX

The Supreme Court held that the Ganga Bai Charities trust was not entitled to exemption under Section 11(1)(a) of the Income Tax Act, 1961, as the trust deed did not specify the application of income for religious or charitable purposes. The Court emphasized that the statutory exemption hinges on the actual application of income rather than merely the income earned from the trust property. The appeals by the assessee-trust were dismissed, affirming the High Court's negative answer regarding the entitlement to exemption.