T. A. BUKTE, J.M.: These appeals are filed by Revenue against order of AAC of IT, Pune Range, Pune, dt. 31st Oct., 1983. AAC has directed ITO to exempt income of assessee under ss. 11 and 13 of IT Act, 1961. Revenue s grievance is that in fact benefits of association are restricted only to members of association and, therefore, assessee, association was not entitled for exemption under ss. 11 and 13 of IT Act. Hence, these appeals. All these appeals are heard together and they are disposed of by this common order for sake of convenience. assessee association is institution registered under Societies Registration Act, 1960. said institution has been set up with objects as below: "The objects of Association are: (a) To undertake, carry on, or help to carry on, research and other scientific work in connection with sugar trade or industry, including sugarcane cultivation, and other trades or industries allied therewith or accessory thereto. research and other scientific work will include research and scientific work in, among others, following directions.: (i) To promote increase of knowledge regarding science and practice of sugar technology, including sugarcane cultivation and other kindred branches of this industry; (ii) Investigation into usability and manufacture and improvement of materials used in sugar industry and other trades or industries allied therewith; (iii) Investigation into method of utilisation of products and bye products of sugar industry; (iv) Investigation into improvement of various machinery and appliances used by sugar industry and other trades or industries allied therewith and developing new machinery and appliances for manufacturing, testing and recording purposes, and; (v) Investigation into improvement of various process of manufacture with view to securing greater efficiency, rationalisation and reduction of costs. (b) To establish, equip and maintain laboratories, workshops, factories, farms, research stations or any of them or all of these and conduct and carry on experiments and to provide funds for such work and for payment to any person o r persons engaged in research work, whether in such laboratories, research stations elsewhere and to encouraged and to improve education of persons who are engaged or are likely to be engaged in said industry and other trades or industries allied therewith; (c) To prepare, edit, print, publish, issue, acquire, and circulate books, papers, periodicals, gazettes, circulars and other library undertakings, treating of or bearing upon said industry or other trades or industries allied therewith or any of them or to matters of interest to members thereof, and to translate, compile, collect, publish, lend and sell and endeavour to secure or contribute to translation, compilation, collection and publication by Govt. Departments and other bodies or persons of any such literature, statistics and information and to disseminate same by means of reading of papers, delivery of lectures, giving of advice, appointment of advisory officers or otherwise; (d) To retain and/or employ, skilled, professional or technical advisors or workers in connection with objects of association and to pay therefor such fees or remuneration as may be thought expedient, also to found, aid or maintain schools or colleges for sugar and sugarcane or any allied research and endow scholarships and bursaries for remuneration, instructions and support of students in research work or persons engaged in studying principles involved in said industry and other trades or industries allied therewith, or connected therewith, whether in laboratories of Association or elsewhere, and to employ and remunerate, as may be expedient, instructors and supervisors for such students and also for persons engaged in studying principles involved in said industry and other trades or industries allied therewith or connected therewith; (e) To encourage discovery of, and investigate and make known nature and merits of inventions, improvements processes, materials and designs which may seem capable of being used by members of Association for any of purposes of said industry and other trades or industries allied therewith o r any of them, and to acquire any patents, or licences relating to any such inventions, improvements or processes, and to acquire and register any designs or standardisation marks, whether for general or special purposes, with view to use thereof by members of Association and others upon such terms as may be expedient and to develop, perfect and test value of such inventions, improvements, processes and designs by manufacturing, exhibiting and placing o n market any article or substance to which same may be capable of application; (f) To apply to Government, public bodies, urban/local municipal, district and other bodies, corporations, companies or persons for and to accept donations in money or in kind, subscriptions and raise loans or collect money by any other suitable or collect money by any other suitable means with view to promoting objects of Association and to discuss and negotiate with Govt. Departments, public and other bodies, corporations, companies, or persons scheme or research and other workers and matters within objects of Association and to conform to any proper conditions upon which such grants and other payments may be made; (g) To arrange meetings, lectures and discourses for discussing technical matters, for advancement of technical matters, for advancement of technical knowledge of sugar industry; (h) To promote exchange of views and informations regarding sugar and sugarcane technology amongst members by providing opportunities for personal contacts, visits or by way of any other methods likely to help in achieving this object; (i) To provide opportunities for exchange of knowledge amongst members of profession and their friends and to give facilities for reading of papers and delivery of lectures on subjects interesting to profession, and for acquisition and dissemination by these and other means of information connected with and useful to profession; (j) To look after interest of members of Association, to bring about standard of professional etiquette, better employment conditions and general betterment of their knowledge; (k) To promote and hold, either alone or jointly with any other association, institution, person or persons, competitions to encourage efficiency drive in any sphere of activity of sugar industry and to get maximum yield of sugarcane per acre and any other competitions conductive to maximum production per unit and to offer, give or contribute towards prizes, competition or competitions; (l) To undertake all other activities which are found necessary or helpful for fulfilment of objects of Association." institution had enjoyed exemption under s. 35(1)(ii) of IT Act period from 1st April, 1974 to 31st March, 1977. benefit was not extended s assessee was advised that it could more appropriately fall under s. 10(23A). This application is pending. This institution was not registered under s. 12A of IT Act by CIT, Pune, though petitioner had applied in time. ITO has held that provisions of ss. 11, 12 and 12A are not fulfilled by assessee. assessee association s contention before ITO was that income o f institution is exempt under s. 11. In alternative on basis of mutuality, question of earning any income did not arise. institution is doubtless oriented for benefit of members. ITO rejected this claim also. According to him, all contributories to common fund must be participators in surplus. There must, thus, be complete identity between contributors of fund and participators in surplus. ITO held that as members are not entitled to participate in surplus, institution cannot get benefit of mutuality. argument that institution has been established for advancement of sugar trade and industry in general and thus fruits of research made by institution are available to all interested persons was also rejected. ITO thus held that income of institution is liable to be taxed under provisions of IT Act. assessee being aggrieved by order of ITO went in appeal before AAC. AAC took note of facts that assessee s income was exempt under s. 10(21) of IT Act upto asst. yr. 1978-79 and certificate under s. 80G was also issued to it. AAC held that primary and dominant object of assessee-association is to promote knowledge regarding science and practice of sugar technology, including sugarcane cultivation, etc. other incidental objects are to look after interest of members of Association, to bring about standard of professional etiquette, better employment conditions and general betterment of their knowledge. We have gone through constitution of association. membership is open to all persons who are interested in studying developments in filed of sugar/sugarcane technology. fruits of research made by association reach to every person in society. activities of association are benefiting sugar industry and sugarcane cultivators. benefits are available to members and general public interested in this line of business. Therefore, object of association constitutes charitable purpose as defined in s. 2(15) of IT Act. word public does not mean whole world but cross-section of population identifiable with reference to impersonal or public character. assessee association satisfies conditions laid down under ss. 11 and 13 and, therefore, it is entitled for exemption. association is enjoying approval under s. 35(1)(ii) and its income is held exempted from Income-tax under s. 10(21) and also under WT Act under s. 5(1)(i). As association has been granted recognition under s. 80G for period from 1st April, 1972 to 31st March, 1980 and, therefore, it would not be correct to say that association is not charitable institution and it is not entitled for exemption. association has filed return of income for asst. yr. 1978-79 and claimed exemption under principle of mutuality. ITO refused this claim and he has made specific finding in his order that "in fact institution has been established for advancement of sugar trade and industry in general and fruits of research made by institution are not restricted only to members." ITO has refused to give benefit of ss. 11 and 12 on ground that CIT has refused registration under s. 12A. It is, however, seen that later on, CIT has granted registration on 30th Nov., 1983 on footing that registration under s. 12A does not mean acceptance of claim under s. 11. association has main object of undertaking research and scientific work i n connection with sugar trade. It has held several conventions and nearly 1000 papers have been presented, discussed and published. These paper are on subject or sugarcane cultivation and sugar manufacture, sugar engineering and by product of sugar industry. These paper are prepared by technologists and scientists from various Universities on research carried on in subject. These papers and subjects dealt therein enable technologist to acquaint themselves with latest techniques adopted in sugar industries. It helps industries to improve its efficiency and it results in reducing cost of sugar. consumer and general public are beneficiaries of research as research leads to reduction in cost of production covered in consumer price and improvement in quality. Similarly, seminars are held on important topics. These details are given on page 15 of paperbook. So far association has held 55 seminars. association has published special reports in details. Looking at objects and actual functioning of association, there cannot be any doubt that objects do constitute charitable purpose within meaning of s. 2(15) of IT Act. No benefit can be said to be restricted only to members. All clauses should be read together and if so done, main object is to include research and scientific work in sugar industry and all other objects are incidental. Any benefit if at all stated to be in Supreme Court (sic) in case of CIT vs. Bar Council of Maharashtra (1981) 130 ITR 28 (SC). In view of above discussed facts, we are unable to accepted contention of senior Departmental representative Shri A. P. Walvekar that objects of assessee association are not charitable under s. 2(15) of IT Act, 1961. According to Shri Walvekar what is contemplated is general public and that does not amount to charitable purpose. Shri Walvekar has particularly referred to cl. 2(j) from Memorandum of Association (reproduced in para 3 above). This clause deals with employment conditions of members and does not enure for benefit of public. cl. 2(j) is distributive and not ancillary to other objects assessee would lose benefit of exemption under s. 11. Shri Walvekar relied on decision of Gujarat High Court in Add. CIT vs. Ahmedabad Millowners, Association (1977) 106 ITR 725 (Guj) and Headnote from page 726. learned representative for assessee association has stressed upon all clauses of Memorandum of Association to find out true meaning from said clauses. According to him, true meaning of all clauses including alleged offending cl. 2(j) constitute charitable. impugned clause is not distributive but ancillary to main clauses, viz., advancement of object of public utility. We have gone through orders of authorities below and also paperbook. We hold that all objects of clause constitute advancement of object of public utility not involving activities for profit. Clauses 2(j) is ancillary and not independent object and hence Gujarat judgment relied upon by Departmental Representative is not applicable. As rightly pointed out by AAC public does not mean whole world. If any member of public can become member and if ultimate benefit goes to members and others, conditions of s. 2(15) can be said to be fulfilled. There is no occasion for refusal of membership to anyone so far. Sec. 12A requires only application to CIT and not actual grant of registration under s. 12A. Accordingly order of AAC is upheld Appeals are dismissed. *** INCOME TAX OFFICER v. DECCAN SUGAR TECHNOLOGISTS ASSOCIATION.