JUDGMENT

Paripoornan, J.-The appellant is a trust. The Trust was created on 4.6.1962. The trust called "Thiagarajar Charities" is an assessee to income tax. In this batch of appeals, we are concerned with the three assessment years 1964-65, 1965-66 and 1966-67. A common question of law arises for consideration herein. The Income-tax Appellate Tribunal referred two identical questions of law for the above three years, to the High Court of Madras for its decision. The questions of law referred for the above three years are as follows:-

"Whether on a proper construction of the trust deed dated 4.6.62, the Tribunal was right in holding that the objects of the trust are not for charitable purposes within the meaning of the said expression as defined in Section 2(15) of the Income tax Act, 1961, and that consequently its income for the assessment years 1964-65 and 1965-66 is not exempt from tax under section 11 of the Income-tax Act 1961?"

"Whether on a proper construction of the trust deed dated 4.6.1962 the Tribunal was right in holding that the objects of the trust are not for Charitable purposes within the meaning of the said expression as defined in Section 2(15) of the Income-tax Ac