Charitable trust exemption denied for Bar Council fee receipts from enrolment and apprenticeship administration under income-tax law.

Fees received by a Bar Council for enrolling advocates and registering apprentices were held not to be income derived from property held under trust or other legal obligation for religious or charitable purposes within Section 4(3)(i) of the Income-tax Act, 1922. The receipts arose from administrative and statutory functions, and the exemption applied only where the income itself was derived from property so held. As the fee receipts did not satisfy that requirement, they were not exempt from income-tax, and the reference was answered in favour of the Revenue.

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Issues: Whether fees received by the Bar Council for enrolling advocates and registering apprentices constituted income derived from property held under trust or other legal obligation wholly for religious or charitable purposes so as to be exempt under Section 4(3)(i) of the Income-tax Act, 1922.

Analysis: The receipts in question arose from the Bar Council's administrative functions in maintaining the list of advocates and registering apprentices. They were not income derived from property held under trust or other legal obligation within the meaning of the exemption provision. The exemption applied only where the income itself was derived from property so held, and the Bar Council's fee receipts did not satisfy that requirement.

Conclusion: The receipts were not exempt from income-tax under Section 4(3)(i) of the Income-tax Act, 1922, and the answer to the reference was in the negative, in favour of the Revenue.

Ratio Decidendi: Income is exempt under the charitable trust provision only when it is derived from property held under trust or other legal obligation for the specified charitable purposes; fee receipts from statutory or administrative functions do not qualify.

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