1. The assessee is a private company limited by guarantee and it was incorporated on the 31st August 1944. Before the incorporation the Association had passed a certain resolution and that resolution was that after rationing week S6 and since 57th week, Mobadla at the rate of 8 annas per bag is to be collected from every rationing shop and for the shops which have registered less than 1,000 units on rationing cards Mobadla at the rate of 4 annas per bag is to be charged. Out of the proceeds of the Mobadla thus collected as above 25 p.c. will be utilised towards office expenses and charity and the balance of 75 p.c. will be distributed amongst members as Mobadla. Therefore, briefly, the scheme was this. It was not possible for all members of the Association to get a ration card. The Association used its good office to get ration cards for some of its members. As these members benefited by obtaining ration cards and other members were with out ration cards, those who obtained ration cards were made to compensate those who had not, and the scale of compensation was laid down. The contention of the Income-tax authorities was that the surplus of 25 p.c. after legitimate deduct