P. CHAKRAVARTTI, C. J.

( 1 ) THIS is a Reference under Section 66 (2) of the Income-tax Act made by the Income-tax Appellate Tribunal at the direction of this Court of two questions of law arising out of three assessments of the Cricket Association of Bengal, The question referred is practically a single question, but it has been split up into two separate questions, because by the time of the assessment for the third year, the law had been slightly changed.

( 2 ) THE Cricket Association of Bengal is an unregistered and unincorporated body. Its membership is open to clubs, District Associations, Universities, Indian States and, subject to certain conditions, individuals. There is no trust deed or other document vesting any property in the Association for any purpose connected with its activities. Its objects are set out in Rule 4 of its Rules under 13 heads, but they may be roughly summarised as promotion of the game of cricket played in accordance with the highest standard, though there are certain subsidiary objects which will not be covered by such a summary. As between its members, it is a mutual association and receives payments by way of subscriptions and donations. The sur

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