Dr. D.Y. Chandrachud, J.

1. The Petitioner is a public trust registered under the Bombay Public Trusts Act, 1950 and conducts educational institutions all over India as well as homes for the elderly, hostels for small children and health centres for the poor and needy. On 14 July 1975, the Petitioner was granted a registration under section 12A of the Income Tax Act, 1961 (`the Act'). On 6 September 1986, an amendment was made to the objects of the Petitioner and as amended, the objects clause, insofar as material, reads as follows :

"3. The Society is established for educational, medical relief, religious and charitable objects for the benefit of women and children in India, primarily Catholics, and in consonant with Catholic principles for all persons irrespective of race, community, caste, religion, language or social status; and in furtherance of the above objects.

(a) To take over, conduct, develop, improve equip, administer and carry on such of the religious educational, medical and charitable institutions, works and activities at present conducted and carried on in India, by the Congregation of the Franciscan Hospitaller Sisters of the Immaculate Conception, a Reli