Religious endowment classification secured tax exemption where historical grants showed property dedicated to worship and charity.

Historical grants, governing documents and surrounding circumstances showed that the villages were dedicated as an Udasi religious endowment for the support of the temple or darbar, with duties of daily worship, sadabrat and other religious observances. The mahant acted only as manager of a mutt-like institution, so the property vested in the institution and not in him personally. The absence of a penal clause did not alter the character of the dedication, and an unproduced written statement could not displace the long-standing documentary and historical evidence. On that basis, the property was treated as held under a legal obligation wholly for religious and charitable purposes, qualifying for exemption from agricultural income-tax.

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Issues: Whether the property was held by the assessee under trust or other legal obligation wholly for religious or charitable purposes so as to qualify for exemption from agricultural income-tax.

Analysis: The institution was found to be an Udasi religious endowment governed by Hindu law, with historical records showing grants and continuance of the villages for the support of the temple or darbar. The documents and surrounding circumstances indicated that the villages were settled as an endowment with obligations to perform daily worship, maintain sadabrat, and support religious observances. The mahant was treated as the manager of a mutt-like institution, the property vested in the institution and not in him personally, and the absence of a penal clause did not alter the legal nature of the dedication. Reliance on an unproduced written statement was rejected as insufficient to displace the long-standing documentary and historical evidence.

Conclusion: The property was held under a legal obligation wholly for religious and charitable purposes, and the assessee was entitled to exemption.

Ratio Decidendi: Where historical grants and governing documents show a religious endowment requiring worship, sadabrat, and related charitable observances, the property is held under a legal obligation wholly for religious and charitable purposes even if the mahant manages the institution and the income is not rigidly earmarked by a penal clause.

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