JUDGMENT

PATHAK, J.:— These appeals have been preferred by the assessee against the judgment of the High Court of Kerala in references disposed of by it under S. 256 of the Act.

2. The appellant is the Dharmaposhnam Company, Irinjalakuda. It is an association constituted under a license issued in January, 1931 by the then Government of Cochin and registered with limited liability under S. 26 (1) of the Indian Companies Act 1913 as applied to Cochin. The appellant was governed by a Memorandum of Association, Cl. (3) of which provided :-

"3. The objects of the company are :

(a) To raise funds by conducting kuries with company as foreman, receiving donations and subscriptions, by lending money on interest and by such other means as the company deems fit.

(b) To do the needful for the promotion of charity, education, industries etc. and public good.

(c) For carrying on the business of the company and for the advancement of the purpose mentioned above in so far as is appropriate, to construct buildings or to purchase or take on lease or for hire movable or immovable properties.

(d) To encourage others to form other institution with the purpose of acting in accordance with the objects of the c