Judgment

SHAH, J. : These six appeals raise a common question as to the liability of the assessees to pay income-tax in respect of certain receipts known as Annadan during the assessment years 1946-47 to 1951- 52. The assessees are a Hindu Undivided family and engage themselves as Pandas or priests who assist devotees in performing worship and ceremonies especially connected with pilgrimage to the temple of Jagannath at Puri, and for services rendered by them they receive certain emoluments which are called Dakshina or Pranami It is not disputed that amounts received as Pranami are profits or gains of business or vocation carried on by the assessees and liable to income-tax. Besides Pranami the assessees collect form the pilgrims amount of money known as Annadan under writings executed by the pilgrims. In these appeals the assessees claim that those amounts are not liable to be included in their taxable income, because they are exempt under Ss. 4(3) (i) and (ii) of the Indian Income-tax Act. The assesses claim that "their estate originally and virtually represents the Guru Gadi created and established for the main purpose of propagating the cult of Lod Jagannath in different