 Good evening, everyone. And amongst us we have Rano Jain, an advocate and a former ITAT member. And she has already done a session with us, which is already very popular. And therefore, when the judgment of the Mobile Education Society was delivered by the honorable Supreme Court, there were a lot of queries because the earlier session was also on the charitable institutional sector. Therefore, as to what will be the impact and what is the gist of this judgment, we requested madam to share her insights and the session will be more like a Hindi English as we normally speak rather than a complete flow of English or complete flow in Hindi. So that we could understand because the judgments in the flow of English has its own impact. While we speak in the dialect in which we normally speak amongst ourselves, gives the better insights on those issues. Being a weekend, you do a webinar around for one hour. She has also consented to take few questions, which would be relevant and in and around revolve with the judgment as such. And I will request ma'am to share her insights over to you and thank you for accepting our invite. Thank you Vikas Ji. Good evening everyone. And thank you once again Beyond Law CLC for inviting me to this August platform. You know, in these last two years, whatever has happened, COVID lockdown and everything, we have lost so many things, but we have got some very good, precious things also. And this Beyond Law CLC, that YouTube channel is a precious one to us because I know at least personally I can say whenever there is a problem related to law points or legal issues, you just have to go to their site, whatever you call it, YouTube channel and just print that and you will definitely find something of your choice or of your, you will get the solution. This is at least my personal experience and I hope all of you agree with me. So I'm very thankful to Vikas Ji to having asked me once again since I already had one occasion to come to this forum. So today we'll be talking about the very latest judgment of the Supreme Court in the case of New Noble Education Society. I'm carrying this judgment with me and in my whatever has been given to me, it is of 33 pages and 78 paragraphs, not a very long one, but still not a very short one also. And you know, I've always heard from this legal fraternity that Income Tax Act is one of the more, in fact, it is the most complicated law and I agree with that. It is actually a very complicated one and it becomes more complicated every year by the number of amendments coming with the budget and finance act, etc. And the subject or the topic on which the most of the number of amendments come, that is charitable trust. I know all of you are agreeing with me. That is the reason the charitable trust issue that has become so complicated and with this finance act 2022 so we are still struggling to understand what the legislature wants, what the government wants us to do, what to do. Because the reason is that the charitable activities have always been from day one, even in the 1922 act, there were a lot of exemptions and a lot of benefits because we all know charity is a virtue and it should be always there in a society, in any society. So always they were given a lot of exemptions, etc. Down the line, I think our government always feels that it is okay to give benefits, exemptions, but in the garb of charitable activities there are people who are making wrong use of these benefits and exemptions. So maybe that is the reason, there are new amendments every year. So this is a very big reason why our act and this charitable trust chapter is getting very complicated. And on top of that, I am not talking about the charitable trust, I am talking about the income tax act. I hope all the income tax practitioners sitting here, they will agree with me. These are the days where our act or our income tax practice is getting very complicated. Our Supreme Court is going very far. I am not criticizing the Supreme Court because it is very important. It is their job to declare law. But sometimes it happens that at the same time, a lot of new laws are created by the Supreme Court. It is not created, it is declared by the law definitely. The settled issues are also unsettled. So these are those days. Now those days are going on. You all know what happened in ESIPF, what happened in 148. So the Supreme Court is increasing the work of our life. And in the charitable trust, two very long judgments have come. One is the new noble education society which we are talking about. There is another one bigger than this, far bigger than this. And far in the sense, it is bigger in the quantum also. There are many pages, a lot has been written. And apart from that, far reaching consequences also. I have talked to Vikazi, we will have a session separately. Because it becomes a little difficult to do both at the same time. So let's talk about the new noble. This is our three judgment. Three judges are sitting in this. It has been written by Justice Ravinder Bhatt. And on the bench, Honorable Chief Justice of India, as he was then, and Honorable Justice Narasimha were there. And what was the story? Now listen. It was a bunch of cases, not only this new noble education, or a lot of other processes involved. The lead case was that of new noble education society, which came from the Andhra Pradesh High Court. What was the issue? The issue was mainly the interpretation of Section 1023C, Section 10 Clause 23C and Sub Clause 6. It was about interpretation. Where it was said that any educational institutions, schools or universities, because they are doing good work, they will get exemption. Subject to certain conditions. But there was a clause. There was a term, I would say, that these institutions existing solely for educational purposes and not for purposes of profit. They will get exemption. So since many times, in 1961 and in 1922, the Supreme Court had a lot of opportunities when they interpreted this sentence and phrase many times. But here too, that was the question. What happened in this new novel? That Andhra Pradesh High Court had hold that you are supposed to exist solely for the purposes of education and not for the purposes of profit. This means that in your objects, there should not be any clause which is indicating anything, any activity, any object, which is not of the nature of education. There was one more question, which is that in Andhra Pradesh, anyone who is doing any charitable activities, it has to get registered compulsorily under the AP Charities Act. It is a long name, I am not taking that. Some AP Charities Act, in which they did not get registered. So the High Court said, if you have not registered, then we will not give you in 1023C in April. Before moving forward, I will tell you about 1023C, where there is an exemption question for any charitable trust, for charitable organization. In Income Tax Act, there are two places where you get exemption. Mainly exemption is in Section 11, which talks about income from a property held under the charitable for the charitable purposes. It will get exemption. Subject 2, many provisors, many explanations are given in Section 11. And the precondition is registration under Section 12A, which is now 12AB. Then you will get exemption. Apart from that, there is no charity in Section 10. Not that you do charity, but if you are doing education or medical work, then there are some different sub clauses for them. That you will get total exemption. As we all know, in Section 10, there is total exemption. But this is also subject to certain provisions, provisors, so many provisors. In Section 23C, how many number of provisors are there? I might not be able to tell you, because the numbering is not there. And the finance that came in 2022, it has put in many new provisors, so there are so many provisors. I will tell you quickly, in 1023C, what are the benefits of educational institutions? There is a sub clause 3AB, which says that the educational institutions will be fully or substantially financed by the government, so they will get this exemption in Section 10. As simple as that. Then there is a sub clause 3AB, which says that those educational institutions, including schools and universities, I will not say all those words. They will also get an exemption, if their annual aggregate income for a specific year is not more than 5 crores. Meaning, you are running a school, you are not financed by the government, you are running a private school, and your annual turnover, annual aggregate turnover for a specific year is less than 5 crores. So you don't have to do anything, you will get an exemption in Section 10. Subject to provisors. Now comes the A, sub clause 6, VI, small roman 6, which was the subject matter in this case, in new novel. This clause deals with those cases, which don't come under 3AB and 3AB. Meaning, you are an educational institution, but you are not financed by the government, fully or substantially financed, and your turnover, or annual aggregate income, is more than 5 crores. In that case, you will get an exemption, provided you get an approval from the principal CIT or CIT. See, this is the story of the approval. Which was exactly the issue before the Supreme Court in this case of new novel society. Now, till here, you will understand. Section 11 says that if you are doing charity, then you will get an exemption, subject to those provisions. For the definition of charity, we go to Section 215, which includes, apart from this education and medical ones, relief to poor, yoga, preservation of monuments, preservation of environment, and other general public utilities. Meaning, whatever you are doing, you will get an exemption. If you are doing charity, then you have not used the word charity in Section 10. Because, maybe the legislator believes that if you are providing education or giving medical facilities, then it is kind of charity. Now, I will come to that very important phrase, which I mentioned earlier. In Section 1023C, there is a phrase, which is said again and again, in every sub-clause of it, university and other educational institutions existing, if they exist solely, SOLELY, solely is the word used, for educational purposes and not for purposes of profit. This word, not in Section 11, talks about its own charity, its own provisors. Actually, the subject matter of this case, starts from here. The main subject matter. There are other issues, I will tell you. I will read it again. Any educational institution or university or school, which exists solely for educational purposes and not for purposes of profit. We only focus on this, exists solely for educational purposes and not for purposes of profit. The problem was that, before the New Noble, all the Supremes, many judgments were made by Supremes. This is not the case before. And, everyone interpreted this phrase, this sentence well. But there is a difference in the approach of Supremes in both the vocations, how to interpret these words. Exists solely for educational purposes and not for the purposes of profit. When I say in Hindi, you exist for educational purposes, but not for profit. Okay? But, and this interpretation was coming to this point, in various cases. I will tell you about the cases. The New Noble, which I said in the beginning, settled law was also unsettled. They said, they will not study it like this. They will study it like this. The institutions existing solely for educational purposes, this is one thing. You are supposed to be exists solely for educational purposes and not for the purposes of profit is something different. First, you have to show yourself existing solely for the purposes of education. Then, the other condition is not for the purposes of profit. The first Supremes was taking both the things together and saying, you exist for educational purposes but not for profit. I tried to explain this in Hindi. Now, it will take a while. Now, as I said, in section 10, 23 C, there are many provisors. For today's discussion, for all the provisors, it is not necessary to study. But I would like to discuss two provisors. One is the second proviso and one is the seventh proviso whose discussion is important in this case. The second proviso gives a procedure. How to get the approval? We are focusing on subclass 6 of section 10, 23 C. So, it is about the approval. The second proviso explains the procedure of the commissioner or the principal commissioner. The seventh proviso is a bit more important. It says, exemption to a business would not be available. Definitely, unless the business is incidental and separate books of accounts are maintained. The seventh proviso talks about this. Now, let's come to the main case, on the judgment. What did the Supreme Court do? First, the minor issues, two minor issues, very minor issues, about which the Supreme Court has discussed. And it has been fixed. It is not that there is a passing reference. And this proposition is holding. I will tell you that first. After that, we will go to the main proposition. The first thing is that the second proviso is written on how to get the approval. The approval procedure is given. You take the principal CIT or CIT. So, they said, actually, there were judgments which said that at the time of the approval, there is no need to the commissioner or principal commissioner to ask for your audited accounts. They don't need it. So, the Supreme Court agreed that there cannot be audited accounts in every case. If you are opening a new institution, if you have not done any work, you will not have audited accounts. But you can ask for this approval at any time. It is not necessary that when you are creating an institution, you can get it later. So, it can be either way. So, they wrote that if you are asking for existing institutions, if you are asking for approval, then CIT or principal CIT has power. It can ask for your audited accounts. Just to check what you are doing, are you existing solely? Because these are the main issues. Because the basic test they said to check whether you are existing solely for educational purposes. They will discuss it because that was the main issue. One, they approved it. The other, the same AP Charities Act, I was telling you because New Naval Noble was existing in Andhra Pradesh. And there is a requirement to get them registered under AP Charities Act. But they did not have registration. So, their argument was that as we always say income tax is a complete code in itself. When it is not written that you will be registered under your local law, you will be registered. And this was a totally settled proposition. I will not say much because there is less time. We all know that whenever there is such a occasion, look, in the last two years there was a amendment. Before that it was discussed in the legislature. Before that there was so many judgments and ITAT decisions are numerous. Where it was held that local laws or any other law other than income tax act we are not concerned with that. Whatever you do, they will take their cognizance. There is no need to deny anyone registration just because he is not complying with the local laws. That is not the thing. But here Supreme Court has written that if according to local law you need to take registration until you take registration you will not get approval in income tax which is a very new proposition. But because Supreme Court has written that we have to take care of that. Now let's come to the main issue. What I said in 1023 C wordings are existing solely for educational purposes and not for the purpose of profit. This interpretation was happening. So the judgment of Supreme Court is quite long but mainly how it happened how it was written and authored that many pages of Supreme Court which were old judgments in which this phrase, sentence, interpretation were mentioned and discussed. Many means the number of decisions of Supreme Court is used almost all of them. Discussed them and then gave conclusions. I'll come to the conclusions later on and I can't discuss many cases because there is no need to discuss all of them but I would like to mention three or four cases. Adityanar Education Society this is a 1997 judgment 224 ITR 310. Discussion This issue was 10 20 22 sorry 10 22 section which is peri material 10 23 see 10 22 23 see 23 see 23 see 23 see 23 see 23 see 23 see 23 see see 23 see 45 So maybe, who directly school college run, but they were assisting to run school colleges, etc. So, Supreme Court, they said that the sole purpose for which the assasin has come into existence is to impart education. They are not going to school college themselves, but their purpose is to impart education at the levels of colleges and schools and so on. Therefore, they will come under the orbit of section 1022. Very simply, Supreme Court said this. And Supreme Court had a very important question in this case, that if surplus arises, if you are going to school or college and when you make your final account, then there is surplus, there is profit. So, can it be said that you are not doing education, you are doing kumai. So, Supreme Court said no. Activity is to impart education. If incidentally some surplus arises, it's okay. You don't get out of this education. And this judgment was given a lot above surplus, that nothing happens with surplus. And I would like to read a sentence from this judgment. He said that decisive or acid test is whether on an overall view of the matter, the object is to make profit or not. So, he said, in a way, the word I want to know now, which has been mentioned a lot in the new novel, pre-dominant object. You know, I didn't use that word, but the sentence I showed you, overall view, that is as good as pre-dominant, the word actually was the bone of contention before the Supreme Court. And in the future judgments, that word has been used in every judgment. So, this happened, Adityanath. After that, Surat Art Silk Plot Manufacturers Association. This is the judgment of 1980, 121 ITR-1, Supreme Court. Look, if you read the new novel, whoever you want to read it, it's a good judgment. Means, there is a lot to read. In that case, there is a lot to read. Again and again and again. Now, it was a five judges, five judges, constitution bench of the Supreme Court. Now, look, whatever case we are reading, new novel, there were three judges in it. So, how did they deal with it? First, let me tell you a little bit about its facts. In this case, the assessor was created for advancement of interest of silk weavers. He had created a society in Surat and to promote export of silk. Basically, he was. But one of the objects in his objects was to buy and sell and deal. Buy and sell and deal in all kinds of cloth, including silk. So, see, in fact, it was an association of silk weavers. It was made for their welfare. But one of the object was to buy and sell. They can sell, they can purchase, they can deal in any kind of cloth, including silk. These were the facts. And this was the first time where the words solely was interpreted by the Supreme Court. But let me tell you this before we move on. Because he was not an educated institution. He was not in school, college, university, no educational institution. They were trying to get exemption under section 11. In section 11, which I said, section 215, the definition of charitable objects. Charity, in fact, which includes relief to poor, medical, education, yoga, conservation of monuments, et cetera, et cetera. And in the end, there is a residual clause which says, objects of general public utility. They actually came into it. Because there was no education, no medical, nothing. They were created for the purposes of general public utility. So, there was no issue of section 1023. It was section 11, but the word solely was discussed. Even in that, it comes solely. Now, what happened in this? It was held to a certain whether the institution carried on the object of making profit or not. Because there is no mention of profit there. You cannot do business. It is the duty of the authority, it was held by the Supreme Court, that the balance of income, when you balance the income, which is saved by surplus, if that is wholly or exclusively to the object for which it is established, that is applied for. If it is applied, it is okay, fine. It is okay if it is surplus, but if they did the object, it is okay. Now, what happened in this new novel? It was mentioned that in Surat-Arts, it is written that solely means predominant. Because this was the case in which the predominant word was used for the first time. It was the word of the Supreme Court. It is written solely, solely means you cannot say it exclusively. You will only do this much work because that is very difficult to do. Meaning, if we think about what the government would have thought when the charitable trust, the organizations, whatever exemptions they would have to give, even if they had as much money as they had, they would have put it in charity. But this is not possible. Accounts will be made yearly. When I make an account in the end, it is very difficult. I have used as much money as I had. If something arises due to surplus or deficit, then the Supreme Court said, in Surat-Arts, by the constitution bench, they said that solely is the word used by the legislature, but that means predominant object. So, take their overall view, which was mentioned in Adityanabh, which I have already told you, so the predominant word has been used from here. So, it started from here. Now, when it was mentioned in the new novel, Surat-Artsil, because there is a lot of mention in it, then how will we distinguish it and how will we get out of it? If you want to get out of it. Because in the new novel of the Supreme Court, it is repeatedly said that there is a meaning of solely which I have already told you that there are two different concepts, solely for education and not for the purposes of profit. First, you have to deal with solely thing. You are working solely for education. Later, tell me if there is profit or not. So, they have written some dictionary meanings of solely. When you read it, you will know. So, how will we deal with it after coming here? This was the Constitution bench in the 5 judges. In our case, there are 3 seats. So, what happened? He did not say, and it will remain very ranking. I did not say the right thing. I totally agree with them. You will agree too. This case of the new novel, the issue was, the question was interpretation of section 1023c and sub clause 6 which deals with school, colleges, universities and educational institutions. There is no mention of the charity or the verity. It is just the mention of education. And Surat Artsil was not interpreting this section. Surat Artsil was talking about section 1112. And the assessment that was existing for the general public utility, the definition of charity in section 215, the residual clause was there. So, they couldn't overrule it. It was the Constitution bench and they didn't even want to do it. So, they came up with a long paragraph and read it. They have distinguished it that Surat Artsil is not relevant in our case. Now, let's come to the American Hotel and Lodging Association Educational Institution. This is a little interesting, so I thought I would tell you. There are two stories in it, solely predominant. But this, this assessment was very interesting. It was a USA based non-profit association whose income was exempted in the US. One branch of it was made in India to comply with its obligation and under various agreements with the Ministry of Tourism, Government of India. There must be something to be done, so it was made here. Now, what do we do? We say that we were providing full and complete curriculum. Listen carefully. Full and complete curriculum recognized throughout the world for hospitality, educational programs in India. I understand the name of the hospital because the name is American Hotel and Lodging Association Educational Institute. So, they said that we provide something related to hospitality to children. It made available textbooks, course material and software programs in relation to hospitality. They used to do this. So, Surat Artsil was used in this case in the Supreme Court. And here, it was said again that Adityanar was a little earlier decision. So, they discussed it as well. And the Supreme Court said, look, their predominant object. Look, if they are doing education, then they are doing it. Then you don't have to go solely. So, this is mainly what I felt we should discuss. Now, let's come to two very important decisions. The three decisions of the Supreme Court, which are a little new and are very much out of my eyes. Look, one of the Punjabi and Haryana in 2010 was the judgment of the High Court of Punjabi and Haryana, Pine Grove. Pine Grove School is probably there. I hope you all remember this very well. There was also a story like this. So, they put these old judgments in great pleasure. Surat Artsil and Haryana in the Supreme Court. But the writing is very good. You can read this case. The writing is very good. I can tell you its citation. It's a 2010 judgment, 327 I.T.R. 73. So, in that, Assisi was favoured. And this predominance theory was propounded. There is nothing solely predominant. It was a good judgment. A little later, no, in fact, a little earlier. There was a judgment of the Uttarakhand High Court, the Queen's Education Society. I hope many of you will remember this. 319 I.T.R. 160. They wrote a little upside down. They said, no, no, it wouldn't be like this. If you got a surplus, then you went out. You are doing business and you are doing something wrong. You are not doing education. And it was a lengthy judgment. A lot of long stories, a lot of Supreme Court who put the Supreme Court. They turned everything upside down. Now, where are we going to keep quiet? The Queen's Education Society and the Fine Growers. Fine Growers, I think I don't remember. Maybe the department went there. All these cases, a lot of cases, went to the Supreme Court. Which is reported. The lead case was Queen's Education. When Supreme Court went there, Supreme Court again discussed Surat Aat and Adityanar. I have already told you that all the cases that are on this topic, open to the Supreme Court and see, all of them are Adityanar. Because it is more of an old judgment. It is a little earlier judgment. And Surat Aat, because it is a long judgment. I have discussed a lot of things. They also, the Supreme Court, there were a lot of assesses on this bunch. They said to Surat Aat that the High Court written by Uttarakhand, Queen's Education, that is not a good law. That is not a good law. And they praised it a lot and relied a lot on the Fine Growers. They promoted Punjab and Haryana and again made pre-dominance theory. They said that it should be a pre-dominant object. Anything else. So these are the cases. Discussion of these cases. Now see, these are all judgments of Supreme Court. So what is new in the new novel? There should be nobility if it is novel. There has to be something novel. There should be something new. So the Supreme Court reversed all these judgments. They specifically wrote that we have overruled the Queen's Education Society case. Because that was a two-judge judgment. So they overruled it. And they again told us the definition of solely. And they said, this solely can never be pre-dominant. You are supposed to exist solely, only, solely for educational purposes. After that, there will be a lot of things and nothing else. Now see, this whole discussion took place in the new novel. I will suggest you to read it in the name of it. It is very well-written and you can understand the history very well. Now they have given some conclusions. I have noted somewhere that they have discussed it up to 64-70. I have already told you that if you need a local law for registration, you will not be given any approval without the income tax act. I am not going to discuss it much, because it was a small issue. It is very relevant for us. Practically, it will definitely be relevant. So what they did was they discussed the AP Charity Act well, section-wise. They wrote it in this section, in this, in this. You cannot exist without it. You can do charity until you have registered in it. Then how will the income tax register you? So they said that after that, they discussed something new in the first 72 months. They gave an example that what is incidental business activity? See, in the section, incidental activity is written in the 7th Proviso, that you can do business incidentally. But they narrowed it down a lot. They gave an example. And they gave incidental business activity in relation to education. See, now it is very important. I have said it again and again, solely existing for education. Now when they have put 7th Proviso in it, now they read it cohesively. When a section itself says that you should be existing solely for educational purposes. And 7th Proviso says that your business is incidental. So they will examine it if you maintain its books separately. So they said, read it cohesively. You are supposed to be existing for education. Now incidental should also be incidental to education. I think, I hope I am making myself clear. They gave an example, Assam State, there is a case of Public Production and Public Publication Corporation Limited, which only publish textbooks. They wrote, Publishing and selling textbooks would be incidental to education. Definitely, because you are making books, you are printing books. That is education. Then they wrote in this judgment, I am not giving this example. Running of own buses for transportation of own students. Take care of it. Can also be treated as incidental. You are running school for your children. You are running buses to give you transportation. Okay, that is also incidental. Similarly, I am reading this judgment. Phraseology. Summer camps, if you have put summer camps, special courses relating to computers, etc. for the benefit of its own students, will also be considered as incidental. I am trying to be more on-going because I feel that practically we are going to face problems here. If we do summer camp, or if we do special classes, or if we do some computer classes, or if we call some children from other schools, then it is possible that the assessing officers will take some adverse inference against us. That is why I was more on-going. Next paragraph, in paragraph 73, he gave another example. He said incidental. He said, if any workshop, seminars, or educational courses in which outsiders are permitted, which I went up to clarify, in any workshop, seminar, or educational courses, any outsiders are permitted to enroll such activity cannot be considered as incidental. Next paragraph. He said, if you are doing something for your students, then it is okay, it is incidental. But if you are doing it for the outsiders, it is not incidental. In the next paragraph, he wrote that cases where the institutions were carrying on the activity of running a hostel, other facilities such as catering only to its own students, this is held to be incidental. Okay. You are running a hostel, or you are catering, but you are doing it for your students, then it is okay. It will be incidental, otherwise it will not happen. So now I will conclude this a little bit. Look, when you will read the judgment, in the end, they have also written their conclusions as A, B, C, D. which are in detail, but the conclusions are the same which I have told you. Three propositions were made. First, that whenever you want to take approval in 1023C, then CIT or principal CIT has the power, they can ask you for audited accounts if you are an existing entity. Secondly, if you need registration in local law, then you do not need any registration. Thirdly, the meaning of solely is solely. First, you are supposed to be existing solely for education. Meaning, all your objects should be related to all the education. And as far as the 7th proviso is concerned, incidental, they clarified it a lot that incidental means your main object of education. It should be exactly related to that. You cannot go a little further. Like, the facilities you are giving to your students, the facilities should also be related to education. You cannot go a little further. So, that incidental will be considered, otherwise incidental will not be considered. So, these were their main propositions. I would like to read a little bit of their language but before that, I will tell you that in the last paragraph, they clarified it because they realized that whatever we are settling, they are unsettling it. They are bringing a huge change. So, what will happen now? Now, it will not change at all. You know, the department will do anything. You will get old gas, open it, open it. So, they clarified it that confusion prevails or chaos prevails. For that, we clarify that this judgment will be applicable after today. So, if you have an approval application pending, it will apply to it. But if it is already approved, it will not apply but practically, I believe that because there will be a year-to-year assessment. They will go to the assessing officer. So, what will happen there? That has to be seen. And I hope they will create a little chaos. Because the department, when they get a judgement in favour of it, definitely, they have the right to do it. They will do it. After that, all the conclusions are in the ABCD. Actually, I will leave it. I do not want to read it. I have not seen Vikas. 45 minutes are over. Vikas, if you have any questions, you can take it. The ultimate conclusion, according to you, would be that the Supreme Court has said that it is a doctorate of prospective overruling. Yes. Exactly. Prospective is... Pardon? Vikas, what I understand practically because we are all practitioners, is that okay. Prospective is... They have clarified it very clearly. It is not prospective. They cannot say anything old. But, let's leave the approval. You take it once. But, the approval is cancelled. And there is an year-to-year assessment. So, how will the department take it? That has to be seen. And I am too sure that there will be a lot of litigation. So, in the light of it, it will be healthy for the professionals. Maybe. As I say, Vikas, how will this happen in our shop? But not that was definitely in light of it. Because the charity in the public, as I had a discussion in my office when it was being held, I was saying a lot that the children's language is like charity. Because for charity, it is a big incentive that we will get benefits in the income tax. Now, it is very difficult to get benefits. And now, we have just talked about this judgment. Vikas, the last year in the Act or the Finance Bill, I say that the amendments are so big that they are making it so difficult. I feel that either the charity will be closed or the charity people will come and keep the income tax at their level. Which is very difficult. Because the charity is very important to get benefits. Otherwise, the charity will suffer. And the importance of charity is more than that that no one will know in the last two years. COVID cannot survive without charity. PSR, like corporate social responsibility is also another thing. Yes, yes. So, sometimes it's the carrot and the stick theory that if you incentivize someone, then people do more of it. Yes, I understand. I understand the government's dilemma, which I also said in the beginning. People get benefits, right? But the general activities that are being done in the process of removing the benefits, they are also being harmed. Let's see, something will happen, something will happen. It will be dealt with in time. Yes, yes. And any judgment also, they say that's why the constitution is a living institution. Same as the judgments, it keeps on changing. And that's why they say that everything is permanent except the change. Yes, exactly, exactly. So, I will just check out because here nobody has shared the view. Any question? No, here also. So, you are given a food for thought for everyone to how things can be looked forward. And they also say that the more judgments they come, once there is ample discussions on different social media and otherwise also, it will half upon. And again, as we normally say, the views are personal of the speaker. And those who can take insights, they can accept the judgment as it is, number one. Number two, if you feel that there can be insights, after all, a lot of discussions and debates give rise to new horizons, new mindsets for everyone. So, we believe that we will have a new era of discussions thereafter also, after the session also. So, thank you everyone for connecting with us on the weekend. Stay safe, stay blessed, Namaskar.