Judgment

GROVER, J.:- These appeals (C. As. 1284.1286/71) are by special leave from a judgment of the Gujarat High Court in an Income Tax Reference. Originally the appeals had been filed by certificate (C. As. 2146-2148/68) but that was found to be defective as no reasons were stated therein.

2. The Reference relates to the assessment years 1960-61, 1961-62 and 1962-63 the relevant accounting years being the financial years ending 31st March 1960, 31st March 1961 and 31st March 1962. During the relevant years the assessee which is an association of persons held various properties for the purposes set out in its constitution. It is unnecessary to refer to all the clauses therein. It would suffice to mention that among the objects and purposes of the institution were the management of the movable and immovable properties of the Rana community of the city of Ahmedabad, doing acts to improve the education in the community, to give medical help to the community etc. The Income-tax Officer took the view that the objects were not charitable and therefore the assessee was not entitled to the exemption under Section 4 (3) (i) of the Income-tax Act, 1922. The Appellate Assistant Commissioner h