JUDGMENT

BHAGWATI, J. (for himself and on behalf of N.L. Untwalia and V.D. Tulzapurkar, JJ.) (Majority view):- These tax references have been made by the Tribunal directly to this Court under S. 257 of the Income-tax Act, 1961 (hereinafter referred to as the Act), since there is a conflict of opinion amongst different High Courts as to the interpretation of the words "not involving the carrying on of any activity for profit" occurring at the end of the definition of charitable purpose in cl. (15) of Sec. 2. Originally these references came up for hearing before a Bench of three Judges but having regard to the great importance of the question involved and the serious repercussions, which an adverse decision might have on a large number of public trust in the country, the Bench thought it desirable to refer the cases to a larger Bench and that is how these references have now come before us.

2. Though the references are six in number, they relate to the same assessee and raise the same question, only the assessment years being different. The assessee is the Surat Art Silk Cloth Manufactures Association, a company incorporated under the Indian Companies Act, 1913. The original Memorand