As per the case facts this case concerns the definition of 'charitable purpose' under the Income Tax Act particularly regarding entities involved in activities that might be considered trade or ... business Various statutory corporations and regulatory authorities are involved claiming exemption as institutions with charitable purposes The question arose as to what kinds of income or receipts may not be characterized as derived from trade commerce or business for a consideration especially for organizations involved in general public utility Finally the Supreme Court examined the interpretation of Section of the IT Act and how it relates to activities in the nature of trade commerce or business particularly for entities like statutory corporations and organizations providing services for the benefit of trade and business concluding that certain activities while for public utility might still generate significant receipts from trade business affecting their exemption claims