Widow's United Nations pension remains tax-exempt where it is attributable to the deceased employee's service.

Pension paid to the widow of a United Nations employee from the United Nations Joint Staff Pension Fund was treated as a continuation of the deceased employee's service-related pension and remained exempt from tax. The exemption was supported by section 18(b) of the United Nations (Privileges and Immunities) Act, 1947, read with article 35 of the Fund Regulations, which preserved the pension's exempt character where it was attributable in substance to the employee's UN service. The question was therefore answered against the Revenue and in favour of the assessee.

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Issues: Whether pension received by the widow of a United Nations employee from the United Nations Joint Staff Pension Fund was exempt from tax under the Income-tax Act, 1961.

Analysis: The pension received by the widow was treated as a continuation of the pension payable by reason of the deceased employee's service with the United Nations. The exemption was supported by the effect of section 18(b) of the United Nations (Privileges and Immunities) Act, 1947, read with article 35 of the United Nations Joint Staff Pension Fund Regulations, and the question was answered consistently with the view that such pension retains its exempt character.

Conclusion: The pension amount was exempt from tax, and the question was answered against the Revenue and in favour of the assessee.

Ratio Decidendi: Pension payable to a widow of a United Nations employee, where it is in substance the pension attributable to the deceased employee's service, is exempt from tax under the relevant immunity framework.

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