Registered trade union as "individual" for wealth-tax when treated as a separate body corporate under the statute.

A registered trade union is treated as a body corporate under the Indian Trade Unions Act, 1926, with separate legal existence, perpetual succession, a common seal, and capacity to hold property and sue or be sued in its own name. On that statutory scheme, the term "individual" in the Wealth-tax Act, 1957 is used in a broad charging sense and is not confined to natural persons. A trade union is therefore not excluded from that expression and is 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: Section 3 of the Wealth-tax Act, 1957 adopts the term "individual" as a charging unit in a wide sense. The meaning of that expression, as settled by judicial authority, is not confined to natural persons and may extend to a group of persons forming a unit or to a juristic entity. A registered trade union is incorporated by Section 13 of the Indian Trade Unions Act, 1926 as a body corporate with perpetual succession, a common seal, and power to hold property and sue or be sued in its own name. Section 14 excludes its treatment as a society, cooperative society, or company under the specified enactments. On that statutory scheme, the union has an independent legal existence and is not excluded from the expression "individual" in the Wealth-tax Act.

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

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