Hindu deity as a juristic person may be assessed as an individual through its shebaits under income tax law.

A Hindu idol was recognised as a juristic person capable of holding dedicated property, with the shebait acting only as the human manager through whom that property is preserved and administered. The word "individual" in section 3 of the Income-tax Act, 1922 was held wide enough to include juristic entities and not limited to natural persons. Section 2(31) of the Income-tax Act, 1961 was treated as confirming that artificial juridical persons fall within the taxable concept. On that basis, the deity could be assessed as a taxable unit through its shebaits, and the issue was answered in favour of the Revenue.

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Issues: Whether a Hindu deity is a juristic entity capable of being treated as an individual under section 3 of the Income-tax Act, 1922, and whether assessment on the deity through its shebaits was in accordance with law.

Analysis: A Hindu idol is recognised in law as a juristic person in whom dedicated property vests, while the shebait or manager is the human agency through whom the property is preserved and managed. The word "individual" in section 3 of the Income-tax Act, 1922 was held not to be confined to human beings, but to be wide enough to include juristic entities. The later statutory definition in section 2(31) of the Income-tax Act, 1961 was treated as a parliamentary exposition confirming that artificial juridical persons fall within the concept. On that basis, the deity could be assessed as a taxable unit through its shebaits.

Conclusion: The issue was answered in the affirmative and in favour of the Revenue.

Ratio Decidendi: A Hindu deity, being a juristic person, falls within the expression "individual" in section 3 of the Income-tax Act, 1922 and may be assessed as a unit through its shebaits.

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