COMMISSIONER OF INCOME TAX vs DAWOODI BOHARA JAMAT

Whether the determination of the nature of a trust as wholly religious or charitable is a question of fact or law --- Held: It is a question of law involving examination of the legal effect of proven facts/documents. Whether the respondent-trust, with objects benefiting the Dawoodi Bohra community, is a public religious trust outside the purview of Section 13(1)(b) and eligible for exemption under Section 11 --- Held: No. The trust's objects are not wholly religious but include charitable purposes, and being for the benefit of a particular religious community, Section 13(1)(b) is attracted, denying exemption.