JUDGMENT

KHANNA, J. (for himself and on behalf of Gupta J.):—The detailed facts of this case have been given in the judgment of our learned brother Beg J. and need not be repeated. The question of law which was referred to the High Court and which has been answered in the negative against the assessee-appellant is as follows:

"Whether on the facts and in the circumstances of the case, the income 12 of the Lok Shikshana Trust was entitled to exemption under Section of the Income-tax Act, 1961 read with Section 2(15) of the same Act, for the assessment year 1962-63"

"Charitable purpose was defined in Section 4 (3) of the Indian Income-tax Act, 1922 asunder:

"In this sub-section charitable purpose includes relief of the poor, education, medical relief, and the advancement of any other object of general public utility."

The definition of "charitable purpose" as given in Sec. 2(15) of the Income tax Act, 1961 (hereinafter referred to as the Act) with which we are concerned reads as under:

"(15) Charitable purpose includes relief of the poor, education, medical relief, and the advancement of any other object of general public utility not involving the carrying on of any activity for pr