Supported findings of fact and religious offerings intended for the institution were held exempt, not personal income.

Off-rings made at the feet of a spiritual head were treated as income of the charitable religious institution, not the individual, because the Tribunal found on evidence that he disclaimed any personal interest, the receipts recorded the amounts as received for the institution, and the surrounding facts showed an intention to benefit the religious body. In reference proceedings, supported findings of fact cannot be reopened by the High Court merely because another view is possible. On that material, the offerings were exempt as institutional income under section 4(3) of the Income-tax Act, 1922, and not taxable as the assessee's personal income.

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Issues: Whether offerings made at the feet of the spiritual head were his personal income chargeable to tax or income of the charitable religious institution exempt under section 4(3) of the Income-tax Act, 1922; and whether the Tribunal's factual findings in the reference could be disturbed.

Analysis: The Tribunal had found that the assessee disclaimed any personal interest in the offerings, that the receipts described them as received for the institution, and that the offerings were intended for the religious body rather than for the assessee's personal use. In reference jurisdiction, such findings of fact, if supported by evidence, bind the High Court and cannot be reopened merely because another view is possible. The Court held that the assessee's statement, supported by the receipt and the surrounding facts, was sufficient material for the Tribunal's conclusion, and that the department had not properly challenged any alleged evidentiary defect in the reference.

Conclusion: The offerings were not the assessee's personal income and were exempt as income of Sant Nirankari Mandal under section 4(3) of the Income-tax Act, 1922.

Final Conclusion: The common question was answered in favour of the assessee, and the receipts were treated as exempt income of the institution rather than taxable income of the individual.

Ratio Decidendi: In income-tax reference proceedings, supported findings of fact recorded by the Tribunal are binding on the High Court, and voluntary offerings shown on the evidence to be intended for a religious charitable institution are exempt rather than taxable as the personal income of the office-holder.

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