THE COMMISSIONER OF INCOME-TAX, BOMBAY vs SMT. KASTURBAI WALCHAND TRUST, BOMBAY

The Supreme Court held that the income from the trust properties was exempt from tax under Section 4(3)(i) of the Income Tax Act, 1922, after the respondent executed a deed of surrender on July 21, 1955, renouncing her beneficial interest. The Court clarified that once a valid trust is executed, the property vests in the trustees, and the income is considered the income of the trust, not the beneficiaries. Therefore, after the surrender, the properties were held wholly for charitable purposes as specified in the trust deed, and the income accrued thereafter was for charitable application.