Registered trade union treated as an individual for wealth-tax purposes because it is a separate juristic entity.

A registered trade union constituted as a body corporate under the Indian Trade Unions Act, 1926 is within the wide charging meaning of "individual" under the Wealth-tax Act, 1957. The term is not confined to a natural person and may extend to a juristic person or corporate unit with independent legal existence. Because the union has perpetual succession, a common seal and capacity to hold property, it is treated as an independent juridical entity rather than a mere association, and is therefore chargeable to wealth-tax in the status of an individual.

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Issues: Whether a registered trade union, being a body corporate under the Indian Trade Unions Act, 1926, is chargeable to wealth-tax in the status of an individual.

Analysis: The expression "individual" in the charging provision of the Wealth-tax Act, 1957 has consistently been given a wide meaning and is not confined to a natural human being. It includes a group of persons forming a unit and may extend to a juristic person or corporation. A registered trade union is created as a body corporate with perpetual succession, a common seal, capacity to hold property, and an independent legal existence. The exclusion of trade unions from the operation of the Societies Registration Act, the Co-operative Societies Act and the Companies Act further shows that its status is not that of a society, company or mere association, but of an independent juridical entity. On that basis, it falls within the charging term "individual" for wealth-tax purposes.

Conclusion: The registered trade union is chargeable to wealth-tax as an individual and the objection to assessment fails.

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