Wealth-tax charging provision cannot expand "individual" to cover an omitted association of persons, protecting registered associations from tax.

A registered association formed for community welfare was examined only for its wealth-tax status under the charging provision. The court applied the principle that an association of persons cannot be taxed as an individual where the Legislature has not expressly brought such entities within the charging section. The term "individual" was not given an expanded meaning to include entities deliberately omitted from the taxable net. On that construction, the association was not liable to wealth-tax as an individual, and the reference was answered in favour of the assessee.

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Issues: Whether a registered association could be treated as an individual, association of persons, or body of individuals for the purpose of wealth-tax liability under the charging provision.

Analysis: The association was registered for community welfare and the dispute was confined to its tax status under the Wealth-tax Act. The ruling relied on the principle that an association of persons cannot be brought within the charging provision as an individual when the Legislature has not included such entities within the taxable net. The expression "individual" was held not to be expansively construed so as to cover entities deliberately omitted from the charging section.

Conclusion: The assessee was held not liable to wealth-tax as an individual, and the answer to the referred question was in favour of the assessee and against the Revenue.

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