Voluntary receipts from a vocation are taxable income when they arise from systematic religious and propaganda activity.

Receipts voluntarily remitted by supporters were taxable where they had a direct and intimate connection with the assessee's systematic religious and ideological activity and his newspaper and propagation work. Such sums arose from the exercise of an occupation or vocation, so they did not lose their taxable character merely because they were occasional or voluntary. The exemption for casual and non-recurring receipts under section 4(3)(vii) did not apply because the payments sprang from the assessee's vocation rather than from personal gifts or testimonials. The receipts were therefore assessable as income and not exempt.

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Issues: Whether the sums received by the assessee were receipts arising from the exercise of an occupation or vocation and therefore assessable as income, or whether they were exempt as casual and non-recurring receipts under section 4(3)(vii) of the Indian Income-tax Act, 1922.

Analysis: The receipts were found to have been remitted by supporters through an associated crusade organisation to help the assessee continue his newspaper and propagation activities. The evidence showed a direct and intimate connection between the assessee's systematic religious and ideological activity and the payments received. The claim that the amounts were merely personal gifts or testimonials based on friendship was not supported by materials on record. Receipts that arise from the exercise of a vocation or occupation do not lose their taxable character merely because they are voluntary or occasional, and the exemption for casual and non-recurring receipts does not apply where the receipts spring from such activity.

Conclusion: The receipts were income arising from the exercise of an occupation and were not exempt under section 4(3)(vii); the answer was against the assessee and in favour of the Revenue.

Ratio Decidendi: Voluntary receipts are taxable when they arise from the systematic exercise of an occupation or vocation, and the exemption for casual and non-recurring receipts does not apply to such income.

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