Wealth-tax liability of a registered trade union turns on juristic personality and the wide meaning of "individual" under the charging provision.

A registered trade union under the Indian Trade Unions Act, 1926 is a body corporate with separate legal existence, and the term "individual" in the Wealth-tax Act, 1957 is wide enough to include a juristic entity capable of holding wealth. On that basis, the union was chargeable to wealth-tax as an individual, and the assessments remained valid even though the Wealth-tax Officer had wrongly described its status as an association of persons. The contrary authority relied on by the assessee was treated as factually distinguishable.

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Issues: Whether a registered trade union is chargeable to wealth-tax as an individual despite the assessment having been made in the status of an association of persons, and whether the assessments cancelling such levy could be sustained.

Analysis: A registered trade union under sections 13 and 14 of the Indian Trade Unions Act, 1926 is a body corporate with perpetual succession, a common seal, power to acquire and hold property, and capacity to sue and be sued in its own name. In the context of the charging provision of section 3 of the Wealth-tax Act, 1957, the expression "individual" is not confined to a natural person and may include a juristic entity or other unit capable of holding wealth. The assessee's registered character and independent legal existence brought it within that assessable category, and the status wrongly mentioned by the Wealth-tax Officer as an association of persons did not defeat the charge. The contrary view relied on by the assessee was held distinguishable on the facts.

Conclusion: The assessee was chargeable to wealth-tax as an individual, and the assessments were valid notwithstanding the misdescription of status as an association of persons.

Ratio Decidendi: A registered trade union, being a body corporate and juristic entity, may be assessed to wealth-tax as an individual under the charging provision even if the assessing authority has described its status incorrectly.

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