THE GURU ESTATE THROUGHDWARKADAS GURU AND OTHERS vs THE COMMISSIONER OF INCOME-TAXBIHAR AND ORISSA

The Supreme Court held that the amounts received by the assessees under the Annadan Patras were not exempt from income tax under Sections 4(3)(i) and (ii) of the Indian Income-tax Act, 1922, as they were not applicable exclusively to religious or charitable purposes. The Court found that the High Court erred in ignoring the Appellate Tribunal's finding that no trust was created and incorrectly assumed a private trust was intended. The Court emphasized that the determination of facts rests with the Tribunal, and the High Court's role is advisory under Section 66(2).