( 1 ) IN these appeals relating to Assessment Years 1957-58 to 1974-75, the main question which is involved for consideration is whether the appellant- trust being a public charitable trust, is eligible for exemption from income tax.

( 2 ) ON 28/11/1941, a partnership deed was executed between K. Rajagopal and V. S. Nanjappa Chettiar. By this document, the said parties a agreed to carry on business in partnership but clauses (4 to (8 of the deed contained an agreement amongst the partners that out of the net profits of the business, after payment of all charges and expenses, 80 per cent shall be set apart and allotted to charitable and religious objects. The amounts which were to be credited to the Charity Account in the books of business were to be utilised by the trustee for carrying out the objects of the Trust. The partnership deed appointed one T. N. Venkatarama Chettiar, son of one of thepartners as the sole trustee. The power which was given to the said sole trustee was contained in para 8 of the deed which reads as follows:

"the said T. N. Venkatarama Chettiar shall from time to time after acceptance of the Trust, operate on the fund in execution of the Trust and spend out o