Law:

Section:

Section 11, read with section 13 of the Income-tax Act, 1961 [Corresponding to section 4(3)(i), read with section 4(3)(ii) of the Indian Income-tax Act, 1922] - Charitable or religious trust - Exemption of income from property held under - Assessment years 1936-37 to 1941-42 - Whether Satsangis are cross section of public, being followers of one religion, and a charitable trust for their benefit must be deemed to be trust for object of general public utility - Held, yes - Assessee Sabha was follower of Dayalbagh School of Radhaswami Satsang - Bhents (offerings) made by followers of Radhaswami faith subsequent to formation of Sabha were deemed to be made to Radha Swamy (deity) through assessee - As a result of said offerings, several institutions, hospitals, ashrams, orphanage and poor house etc. were started and also assessee had started some industrial and commercial concerns - Aforesaid various concerns were not run for individual benefit - Neither income from bhent nor income from business was divisible among Satsangis and no part of income was payable to them or Sant Satgurus - Purpose of setting up commercial establishments was to improve economic amelioration of condition of the Satsangis by giving them training and providing employment -Whether on facts, it could be said that bhents vested in Sabha under legal obligation wholly for religious or charitable purposes of Sabha but they could not be said to be income derived from property under section 4(3)(i) of 1922 Act - Held, yes - Whether income derived from such industrial and commercial concerns was income from property held under trust wholly tax religious or charitable purposes and was exempt from income-tax under section 4(3)(i) of 1922 Act - Held, yes FACTS The assessee Sabha was a body registered under the Charitable Societies Registration Act, 1860. It was a follower of Dayalbagh School of Radhaswami Satsang. All the acquisitions or the properties either moveable or immoveable or in the shape of bhents, offerings, made by the followers of Radhaswami faith subsequent to the formation of the Sabha were deemed to be made by the offerors to Radhaswami (deity) through the Radhaswami Satsang Sabha. The…

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