JUDGMENT

RANGANATH MISRA, C.J.I. :- Radhasoami Satsang, an assessee under the Income-tax Act in these appeals by special leave assails the decision of the Allahabad High Court on reference under Section 256 of the Income-tax Act, 1961. The following question had been referred by the Tribunal to the High Court:

"Whether on the facts and in the circumstances of the case the Tribunal is justified in holding that the income derived by the Radha Swami Satsang, a religious institution, is entitled to exemption under Sections 11 and 12 of the Income-tax Act, 1961?"

2. The ambit and purport of the question would not be properly appreciated unless the background is indicated. The assessee is the Radhasoami Satsang, Agra. This sect was founded by Swami Shiv Dayal Singh in 1861. The tenets of this faith, inter alia, accept the position that God is represented on earth by a human being who is called the Sant Satguru. The first of such gurus was the founder himself and he was popularly known as Soami Ji Maharaj. The second Satguru (1879-1898) was Rai Bahadur Salig Ram and he was known as Hazoor Maharaj. The third Sant Satguru was Pandit Brahma Shanker Misra (1898-1907) and was widely known as Maha