{"id":113459,"date":"1971-09-16T00:00:00","date_gmt":"1971-09-15T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/ahmedabad-rana-caste-association-vs-commissioner-of-income-tax-on-16-september-1971"},"modified":"2019-03-28T12:03:13","modified_gmt":"2019-03-28T06:33:13","slug":"ahmedabad-rana-caste-association-vs-commissioner-of-income-tax-on-16-september-1971","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/ahmedabad-rana-caste-association-vs-commissioner-of-income-tax-on-16-september-1971","title":{"rendered":"Ahmedabad Rana Caste Association vs Commissioner Of Income Tax, … on 16 September, 1971"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Ahmedabad Rana Caste Association vs Commissioner Of Income Tax, … on 16 September, 1971<\/div>\n
Equivalent citations: 1972 AIR 273, \t\t 1972 SCR (1) 744<\/div>\n
Author: A Grover<\/div>\n
Bench: Grover, A.N.<\/div>\n
           PETITIONER:\nAHMEDABAD RANA CASTE ASSOCIATION\n\n\tVs.\n\nRESPONDENT:\nCOMMISSIONER OF INCOME TAX, GUJARAT\n\nDATE OF JUDGMENT16\/09\/1971\n\nBENCH:\nGROVER, A.N.\nBENCH:\nGROVER, A.N.\nHEGDE, K.S.\n\nCITATION:\n 1972 AIR  273\t\t  1972 SCR  (1) 744\n 1971 SCC  (3) 475\n\n\nACT:\nIncome-tax  Act, 1922, s. 4(3) (i) and Income-tax Act,\t1961\ns.  11\tIncome of assessee to be utilised for benefit  of  a\ncommunity-Beneficiaries members of the community resident in\na  city and others admitted according to caste\tcustoms\t and\nusage-If united by common quality of impersonal nature.\n\n\n\nHEADNOTE:\nThe assessee was an association of persons and held  various\nproperties  for\t the purposes set out in  its  constitution.\nOne  of the purposes was the management of the\tmovable\t and\nimmovable  properties of the Rana community of the  City  of\nAhmedabad, doing acts to improve education in the  community\nand  to\t give medical help to the community, etc.   The\t de-\nfinition  of Rana community comprised two classes-one  class\nconsisting  of those who are natives of Ahmedabad while\t the\nother consists of such persons who are admitted by the\tRana\ncaste  according  to  the old custom or\t the  usage  of\t the\ncommunity.\nOn the question whether the income of the assessee-trust was\nexempt\tunder s. 4(3)(1) of the Income-tax Act, 1922, or  s.\n11  of\tthe Incometax Act, 1961, the High  Court  held\tthat\nsince the second class of persons consisted-of those who had\nbeen  accepted\tby  the caste according its  old  custom  or\nusage,\tall  the beneficiaries were not united by  a  common\ncharacteristic\tor  attribute of an  impersonal\t nature\t and\ntherefore, the beneficiaries did not constitute a  community\nor  a section of the Community Allowing the appeal  to\tthis\nCourt,\nAllowing the appeal to this Court,\nHELD : An object beneficial to a section of the public is an\nobject\tof general public utility.  But the section  of\t the\ncommunity  sought  to  be benefitted  must  be\tsufficiently\ndefined and identifiable by some common quality of a  public\nor  impersonal nature.\tThe common quality, in\tthe  present\ncase, uniting the potential beneficiaries consists of  being\nmembers of the Rana caste or community of Ahmedabad  whether\nas  natives or as being admitted to that caste or  community\nunder  custom or usage.\t The mere fact that a person of\t the\nRana  community who is not an original native  of  Ahmedabad\nhas to prove his credentials and according to the custom and\nusage of that community cannot introduce a personal element.\nWhenever  a  question arises whether a person belongs  to  a\nparticular community or caste the custom or usage prevailing\nin that community must play a decisive and vital part.\t The\npersonal  element  or personal relationship  which  takes  a\ngroup  out of a section of the community is  their  personal\nrelationship  to  a single propositus or to  several  propo-\nsition\tor a relationship of a similar\tnature.\t  Therefore,\nthe  members  of  the  Rana caste who  are  not\t natives  of\nAhmedabad  but who come to reside there and are accepted  as\nmembers\t of  that caste according to its usage\tand  customs\ncould  be  said\t to have a  relationship  of  an  impersonal\nnature. [748 B-D; 749 D-G; 750 BvD]\nHazrat Pirmohamed Shah Saheb Roza Committee v.\tCommissioner\nof  Income-tax,\t Gujarat,<\/a>  58 I.T.R.  360,  Commissioner  of\nIncome-tax, Madras v. Andhra Chamber of Commerce,<\/a> 55  I.T.R.\n722,  Re Compton, Powell v. Compton & Ors., (1945) Ch.\t123,\nTrustees  of  the Londonderry Presbyterian Church  House  v.\nCommissioners  of Inland Revenue, 27 T.C. 431 and  Oppenheim\nv. Tobacco Securities Trust Co. Ltd. & Ors., (1951) A.C.\n745\n297, referred to.\n\n\n\nJUDGMENT:\n<\/pre>\n
CIVIL APPELLATE JURISDICTION : Civil Appeals Nos,  2146-2148
\nof 1968 and 1284 to 1286 of 1971.\n<\/p>\n
Appeals\t by certificate\/special leave from the judgment\t and
\norder  dated  July  25, 1967 of the Gujarat  High  Court  in
\nIncometax Reference No. 4 of 1966.\n<\/p>\n
S.   T.\t Desai,\t R.  P.\t Kapoor for I.\tN.  Shroff  for\t the
\nappellant
\n(in allthe appeals).\n<\/p>\n
S.   K.\t Aivar,\t R. N. Sachthey and B. D.  Sharma,  for\t the
\nrespondent (in all the appeals).\n<\/p>\n
The Judgment of the Court was delivered by
\nGrover, J. These appeals (C.As. 1284-1286\/71) are by special
\nleave from a judgment of the Gujarat High Court in an Income
\ntax  Reference.\t  Originally the appeals had been  filed  by
\ncertificate  (C.As. 2146-2148\/68) but that was found  to  be
\ndefective as no reasons were stated therein.
\nThe Reference relates to the assessment years 1960-61, 1961-
\n62  and\t 1962-63  the relevant accounting  years  being\t the
\n,financial years ending 31st March 1960, 31st March 1961 and
\n31st  March  1962.  During the relevant years  the  assessee
\nwhich  is an association of persons held various  properties
\nfor  the  purposes  set\t out in\t its  constitution.   It  is
\nunnecessary  to refer to all the clauses therein.  It  would
\nsuffice\t to mention that among ,the objects and purposes  of
\nthe  institution  were\tthe management of  the\tmovable\t and
\nimmovable  properties of the Rana community of the  city  of
\nAhmedabad,  doing  acts\t to improve  the  education  in\t the
\ncommunity,  to give medical help to the community etc.\t The
\nIncome\ttax Officer took the view that the objects were\t not
\ncharitable  and therefore the assesses was not\tentitled  to
\nthe exemption under s. 4(3) (i) of the Income tax Act, 1922.
\nThe Appellate Assistant Commissioner held that although\t the
\nassessee  was registered under the Bombay Public  Trust\t Act
\nthe  beneficiaries  were  not the public and  the  class  of
\ncommunity  sought to be benefitted was very vague  and\till-
\ndefined and the number was also negligible.  He held certain
\nclauses among the objects to, be charitable but others\twere
\nheld  by him not to be charitable.  The matter was taken  in
\nappeal\tto  the\t Tribunal.   The  Tribunal  held  that\t the
\nbeneficiaries  as  found in the Constitution were  the\tRana
\ncommunity meaning thereby the “natives of Ahmedabad only and
\nother community members accepted by the community as per old
\nrules of the community and staying in Ahmedabad..\n<\/p>\n
746<\/span><\/p>\n
This  is  a  well defined cross-section\t of  the  public  of
\nAhmedabad,  certain and ascertainable.\tThis number, we\t are
\ntold, is about 2,400(?) but no minimum number is  prescribed
\nto  constitute a clear, ascertainable cross-section  of\t the
\ngeneral public.\t It cannot be said, therefore, that there is
\nany  vagueness\tabout the beneficiaries or of  their  public
\ncharacter.”  After  considering\t vanous\t other\tmatters\t the
\nTribunal  came\tto  the\t conclusion that  the  trust  was  a
\ncharitable  trust  and therefore entitled to  the  exemption
\nclaimed.  The Commissioner of Income tax moved the  Tribunal
\nfor  stating  the  case and referring the  question  of\t law
\narising from its order.\t The Tribunal referred the following
\nquestion to the .High Court :-\n<\/p>\n
“Whether  on the facts and in the circumstances of the\tcase
\nthe  income of the assessee trust is exempt under s.  4\t (3)\n<\/p>\n
(i)  of the Income tax Act 1922 and s. 11 of the Income\t tax
\nAct 1961.”\n<\/p>\n
The  High Court decided the whole matter only on one  point.
\nIt considered the question whether the purpose for which the
\nproperties  were  held\tby  the\t assessee  had\tthe   public
\ncharacter which the income tax law required of the charities
\nit  recognised for The purpose of exemption.   The  question
\nthat  was  posed  was ” are the\t purposes  directed  to\t the
\nbenefit\t of the community or a section of the  community  as
\ndistinguished from private individuals or a fluctuating body
\nof  private individuals”?  There can be no doubt,  according
\nto the High Court, that the beneficiaries did not constitute
\na community since they were confined only to the members  of
\nthe Rana Caste residing in Ahmedabad and ful-filling one  or
\nthe  other conditions set out in the definition clause.\t  It
\nhad,  therefore,  to be decided\t whether  the  beneficiaries
\ncould  be  said to constitute a section\t of  the  community.
\nAfter referring to certain English cases and the decision of
\nthis Court in Hazrat Pirmohamed Shah Saheb Roza Committee v.
\nCommissioner  of  Income<\/a> tax, Gujarat (1),  the\t High  Court
\nrightly\t held that the enquiry must be directed to what\t the
\ncommon quality was which united the parties within the class
\nand  whether  that  quality was\t essentially  impersonal  or
\npersonal.  If the former, the class would rank as a  section
\nof  the community if the latter, the answer would be in\t the
\nnegative.  According to the High Court having, regard to the
\ncommon\topinion\t amongst the people and\t the  conditions  of
\n‘Indian\t life if the beneficiaries were the members  of\t the
\nRana  caste  residing  in  Ahmedabad  and  were\t natives  of
\nAhmedabad they would be section of the community because the
\ncommon\tquality\t uniting  them within  the  class  would  be
\nessentially  an\t impersonal  quality.  But  the\t High  Court
\nproceeded to say:\n<\/p>\n
747<\/span><\/p>\n
\t      “the class of beneficiaries before us consists
\n\t      of two sections; one comprising members of the
\n\t      Rana Sect who are natives of Ahmedabad and the
\n\t      other comprising members of the Rana Sect\t who
\n\t      are  residing in Ahmedabad and who  have\tbeen
\n\t      accepted by the community according to the old
\n\t      usage  of the caste.  It is difficult  to\t see
\n\t      how  this class of beneficiaries can be-\tsaid
\n\t      to  constitute  a well section of\t the  public
\n\t      connected\t together  by a\t common\t quality  or
\n\t      characteristic”.\n<\/p><\/blockquote>\n
Although  it  was recognised that even the second  class  of
\nbeneficiaries  were  members  of the  Rana  caste  and\twere
\nresiding in Ahmedabad but the distinguishing feature, in the
\nview  of  the High Court, was that. the\t second\t section  or
\nclass  consisted  of persons who had been  accepted  by\t the
\ncaste  according to its old custom or usage.  This  led\t the
\nHigh Court to conclude that all the beneficiaries  comprised
\nin this class were not united by a common characteristic  or
\nattribute.   The  question  referred  was  answered  in\t the
\nnegative.\n<\/p>\n
Section\t 4(3)  (i) to the extent it is material\t is  in\t the
\nfollowing terms :-\n<\/p>\n
\t      “4(3)  Any  income, profits or  gains  falling
\n\t      within  the  following classes  shall  not  be
\n\t      included\t in  total  income  of\tthe   person
\n\t      receiving them\n<\/p><\/blockquote>\n
\t      (i)Subject to the provisions of clause  (c)
\n\t      of  subsection (1) of section 16,\t any  income
\n\t      derived  from  property held  under  trust  or
\n\t      other legal obligation wholly for religious or
\n\t      charitable purposes, in so far as such  income
\n\t      is  applied or accumulated for application  to
\n\t      such  religious  or  charitable  purposes\t  as
\n\t      relate  to  anything done within\tthe  taxable
\n\t      territories,  and in the case of\tproperty  so
\n\t      held  in part only for such purposes, the\t in-
\n\t      come   applied  or  finally  set\t apart\t for
\n\t      application thereto:\n<\/p><\/blockquote>\n
\t      Provided that…………………”\n<\/p><\/blockquote>\n
The  operative part of S. 11 (1) (a) of the Income  tax\t Act
\n1961  is  in  similar terms.  There are\t certain  points  of
\ndifference between the provisions of the two Acts.  Some  of
\nthem  may be noticed.  In the 1922 Act a charitable  purpose
\nincluded  relief of the poor, education, medical relief\t and
\nadvancement  of any other object of general public  utility.
\nSection\t 2(15) of the Act of 1961 introduces  the  following
\nqualifying words to general public utility, ” not  involving
\nthe carrying on of any activity for profit”.  Under the\t Act
\nof 1922 a trust for the benefit’of any particular  religious
\ncommunity  or caste was entitled to exemption but under\t the
\nAct  of\t 1961 a charitable trust which is created  for\tsuch
\nbenefit on or
\n748<\/span>
\nafterthe  first day of April 1962 would be  disentitled
\nto the exemption. In  the  present  case  the  trust   was
\ncreated prior to first April 1962  and therefore no question
\narises\tof its not being entitled to the exemption if  other
\nconditions were satisfied even though it was created for the
\nbenefit of the Rana caste of Ahmedabad.\n<\/p>\n
It  is\twell  settled by now and the  High  Court  also\t has
\nrightly\t taken\tthat  view that an object  beneficial  to  a
\nsection\t of  the  public  is an\t object\t of  general  public
\nutility.  To serve a charitable purpose it is not  necessary
\nthat the object should be to benefit the whole of mankind or
\nall  persons  in  a  particular country\t or  State.   It  is
\nsufficient  if\tthe intention to benefit a  section  of\t the
\npublic\tas  distinguished  from a  specified  individual  is
\npresent.   This Court in Commissioner of Income tax,  Madras
\nv.  Andhra  Chamber  of Commerce<\/a>(1) overruled  the  view  of
\nBeaumont  C.J.\tin  Commissioner  of  Income  tax  v.  Grain
\nMerchants’  Association of Bombay(2) on the point.  It\twas,
\nhowever,  observed that the section of the community  sought
\nto   be\t  benefitted  must  be\tsufficiently   defined\t and
\nidentifiable   by  some\t common\t quality  of  a\t public\t  or
\nimpersonal  nature.   Where  there  was\t no  common  quality
\nuniting\t the potential beneficiaries into a class the  trust
\nmight  not be regarded as valid.  In the various orders\t the
\nclause\trelating to the beneficiaries has not  been  clearly
\nand  accurately\t set out.  In the petition of  appeal  dated
\nOctober\t 7, 1968 the provisions of the constitution  of\t the
\nassessee are set out and with reference\t to The community it
\nis  stated, “Rana community means natives of Ahmedabad\tonly
\nand  the other community brothers accepted by the  community
\nas per old rules of the community staying in Ahmedabad”.  It
\nis common ground that the word ” old rules” do not represent
\nthe  correct  translation of the original word\tin  Gujarati
\nwhich  is Riwaj meaning custom.\t The learned judges  of\t the
\nHigh Court also, who are conversant with that language, have
\nproceeded  on  the basis that the correct rendering  of\t the
\naforesaid word is custom or usage.  That is why according to
\nthe  High  Court  the definition comprises  two\t classes  of
\nmembers\t of  Rana  caste residing in  Ahmedabad,  one  class
\nconsisting  of those who are natives of Ahmedabad while\t the
\nother class consists of such persons who are admitted by the
\nRana  caste  according\tto the old custom or  usage  of\t the
\ncommunity.   The reason which prevailed with the High  Court
\nfor  treating the second class as not being united with\t the
\nfirst class by a common characteristic or attribute was that
\nits  members have to be accepted by the community  according
\nto the old custom or usage and that the entry of the members
\nof this class into the Rana caste residing in Ahmedabad\t was
\ndependent on the decision of the caste to
\n(1) 55 I.T.R. 722.\t(2) 6 I.T.R. 427.\n<\/p>\n
749<\/span><\/p>\n
admit  them.   We  are altogether unable to  concur  in\t the
\napproach  or the conclusion of the High Court on  the  above
\npoint.\n<\/p>\n
We may usefully refer to the judgment of Lord Greene M.R. in
\nre  Compton, Powell v. Compton & Others(1).  The  Master  of
\nRolls  declared that no definition of what was meant  by  “a
\nsection\t of  the public” had, so far as he was\taware,\tbeen
\nlaid  down.   But he indicated that the trust  of  a  public
\ncharacter is one in which the beneficiaries do not enjoy the
\nbenefit when they receive it by virtue of their character as
\nindividuals but by virtue of their membership of a specified
\nclass  the common quality, uniting  potential  beneficiaries
\ninto  the class being essentially an impersonal\t one.\tThis
\ncommon\tquality he said was “definable by reference to\twhat
\neach  has  in common with the others and that  is  something
\ninto  which  their status as individuals  does\tnot  enter”.
\nAndrew,\t L.C.J.\t accepted  this\t statement  of\tlaw  without
\nhesitation  in\tTrustees  of  the  Londonderry\tPresbyterian
\nChurch\tHouse v. Commissioners of Inland  Revenue(2).\tWhat
\nhas to be seen in the present case is whether the members of
\nthe Rana caste who are not natives of Ahmedabad but who come
\nto  reside there and are accepted as members of\t that  caste
\naccording  to  its usage and customs can be said to  have  a
\nrelationship  which is an impersonal one dependent on  their
\ncondition  as members of the Rana community.  We are  unable
\nto  comprehend\thow such members of the Rana  caste  can  be
\nregarded  as  having  been introduced  into  that  caste  by
\nconsideration of their personal status as individuals.\tAs a
\nmatter\tof fact the predominant content and  requirement  of
\nthe  clause defining “beneficiaries” in the constitution  of
\nthe  assessee is the factum of their belonging to  the\tRana
\ncommunity  of  Ahmedabad.  The\tcommon\tquality,  therefore,
\nuniting the potential beneficiaries into the class  consists
\nof being members of the Rana caste or community of Ahmedabad
\nwhether\t as  natives or as being admitted to that  caste  or
\ncommunity  under  custom  or usage.  The mere  fact  that  a
\nperson\tof the Rana community who is not an original  native
\nof  Ahmedabad has to prove his credentials according to\t the
\ncustom and usage of that community to get admitted into that
\ncommunity cannot introduce a personal element.\tIn Oppenheim
\nv.  Tobacco  Securities\t Trust\tCo.  Ltd.  &  Others(1)\t the
\ntrustees were directed to apply certain income in  providing
\nfor  the  education  of children  of  employees\t or  “former
\nemployees”  of\ta  British limited company  or\tany  of\t its
\nsubsidiary or allied companies.\t It was held by the House of
\nLords  by  a  majority\tthat though  the  group\t of  persons
\nindicated   was\t numerous,  the\t nexus\tbetween\t  them\t was
\nemployment by particular employers and accordingly the trust
\ndid not satisfy the test of public
\n(1) [1945] Ch. 123.\n<\/p>\n
(3) [1951] A.C. 297.\n<\/p>\n
(2) 27 T.C. 431.\n<\/p>\n
75O
\nbenefit\t requisite to establish it as charitable.   This  is
\nwhat Lord Simonds observed –\n<\/p>\n
\t      “A group of persons relationship which takes a
\n\t      group  nexus  between them is  their  personal
\n\t      relationship  to\ta single  propositus  or  to
\n\t      several\tpropositi,  they  are  neither\t the
\n\t      community\t nor a section of the community\t for
\n\t      charitable purposes”.\n<\/p><\/blockquote>\n
The personal element of personal relationship which takes  a
\ngroup  out  of\tsestion\t of  the  community  for  charitable
\npurposes  is of the nature which is to be found in cases  of
\nthe  aforesaid type.  We cannot possibly discover a  similar
\nelement\t of  personal  nature in the  members  of  the\tRana
\ncommunity who settle in Ahmedabad and have been accepted  by
\nthe  Rana  community  of  that\tplace  as  members  of\tthat
\ncommunity.   As\t regards the acceptance of such\t persons  as
\nmembers\t of the community or caste, according to custom\t and
\nusage,\tit  is well known that whenever\t a  question  arises
\nwhether a person belongs to a particular community or  caste
\nthe custom or usage prevailing in that community must play a
\ndecisive  and  vital part.  That cannot be  regarded  as  an
\nelement\t which would detract from the impersonal  nature  of
\nthe common quality.\n<\/p>\n
For the reasons given above the appeals are allowed and\t the
\nanswer\treturned  by  the High\tCourt  is  discharged.\t The
\nmatters\t are  remitted to the High Court for  returning\t the
\nanswer\tto  the question referred  after  determining  the,-
\nother  points which were left undecided.  The parties  shall
\nbear   their  own  costs  in  these  appeals.\tAppeals\t  by
\ncertificate  (i.e. C.As. 2146-2148 of 1968)  are  dismissed,
\nthe certificate being defective for want of reasons.\n<\/p>\n
V.P.S.\t\t\t  Appeals allowed.\n751<\/span>\n\n\n\n<\/pre>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Ahmedabad Rana Caste Association vs Commissioner Of Income Tax, … on 16 September, 1971 Equivalent citations: 1972 AIR 273, 1972 SCR (1) 744 Author: A Grover Bench: Grover, A.N. PETITIONER: AHMEDABAD RANA CASTE ASSOCIATION Vs. RESPONDENT: COMMISSIONER OF INCOME TAX, GUJARAT DATE OF JUDGMENT16\/09\/1971 BENCH: GROVER, A.N. BENCH: GROVER, A.N. HEGDE, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-113459","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nAhmedabad Rana Caste Association vs Commissioner Of Income Tax, ... on 16 September, 1971 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/ahmedabad-rana-caste-association-vs-commissioner-of-income-tax-on-16-september-1971\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Ahmedabad Rana Caste Association vs Commissioner Of Income Tax, ... on 16 September, 1971 - 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