Public Religious Trust status denied where beneficiaries form an ascertainable class; contributions therefore not exempt under section 4(3).

Whether sums received under an Annadan Patra qualified as income applicable solely for public religious purposes under section 4(3) of the Income-tax Act was decided by applying the public v private trust test: the trust benefits were limited to the Panda and a definable class of jajman pilgrims, indicating a private religious trust. The court rejected expanded registry-based beneficiary claims, held the assessee bore the burden of proof and had not discharged it, and concluded the income was not exempt under section 4(3), favouring the Revenue.

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Issues: Whether the sums received by the Panda under the 'Annadan Patra' are exempt from income-tax as income applicable solely for public religious purposes under section 4(3) of the Income-tax Act, 1961.

Analysis: The Court considered the terms of the Annadan Patra and the statutory exemptions in sub-section (3) of section 4 of the Income-tax Act, 1961, which exempts (i) income derived from property held under a trust solely for religious or charitable purposes and (ii) income of a religious institution derived from voluntary contributions applicable solely to religious or charitable purposes. The Court applied the established test distinguishing public and private trusts: whether beneficiaries are the general public or a definable, ascertainable class. The Annadan Patra expressly provided that the Mahaprasad would be available to the Panda himself and to pilgrims from the donor's home district who are jajmans and worship the Panda, a class which is definable and ascertainable and thus indicates a private religious trust. The Court rejected reliance on register entries that expanded beneficiaries beyond the terms of the signed Annadan Patra, and found no sufficient element of public benefit or intention to create a public religious trust. The burden of proving entitlement to exemption lay on the assessee, which was not discharged.

Conclusion: The trust created by the Annadan Patra is a private religious trust; the income derived therefrom is not exempt under section 4(3) of the Income-tax Act, 1961. The result is in favour of the Revenue.

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