Hindu deity as a juristic person treated as an individual for income tax assessment under the 1922 Act.

A Hindu deity was treated as a juristic person capable of holding property, receiving income, and suing or being sued. The term "individual" in the Indian Income-tax Act, 1922 was construed broadly enough to include such a juridical entity, with income assessable through the shebait or manager in possession of the property. The prior view that a Hindu deity falls within the statutory unit of assessment was affirmed, and the deity was held liable to assessment.

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Issues: Whether a Hindu deity is an "individual" within the meaning of the Indian Income-tax Act, 1922 and is therefore liable to assessment.

Analysis: A Hindu deity is a juristic person capable of holding property, receiving income, and suing or being sued. The statutory term "individual" was construed broadly enough to include such a juridical entity, especially where the income is brought to charge through the shebait or manager in possession of the property. The prior decision holding that a Hindu deity falls within section 3 as a unit of assessment was affirmed.

Conclusion: A Hindu deity is an "individual" for the purposes of the Indian Income-tax Act, 1922 and is liable to assessment.

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