UN pension exemption extends to retirement pension, and related compulsory deposit demands fail once the receipts are not taxable.

Pension received by a retired United Nations World Health Organisation employee was treated as exempt under the United Nations (Privileges and Immunities) Act, 1947 because "emoluments" was construed broadly enough to include pension, and pension was also regarded as part of salary for income-tax purposes. As the pension receipts were not taxable, the consequential compulsory deposit demand based on those receipts could not be sustained.

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Issues: Whether pension received by a retired United Nations World Health Organisation employee was exempt from tax, and whether consequential compulsory deposit demands could survive.

Analysis: The pension was held to fall within the exemption available under the relevant provision of the United Nations (Privileges and Immunities) Act, 1947. The reasoning adopted treated the term "emoluments" as wide enough to include pension payable to United Nations officials, and also relied on the statutory understanding that pension forms part of salary for income-tax purposes. Since the pension receipts were not taxable, the foundation for the compulsory deposit demand under the allied enactment also disappeared.

Conclusion: The pension receipts were exempt from tax and the compulsory deposit demands based on those receipts could not be sustained.

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