( 1 ) THIS judgment would dispose of the following six Income-tax References made under Section 66 (1) of the Indian Income-tax Act, 1922 (hereinafter REFERRED TO as the Act):-

(1) Income-tax Reference No. 40 of 1965. The Commissioner of income-tax v. Jaipur Charitable Trust, Delhi.

(2) Income-tax Refernece Nc. 25 of 1965. The Commissoner of Income-tax v. Yogiraj Charity Trust Delhi.

(3) Income-tax Reference No. 42 of 1965. The Commissioner of Income-tax v. Dalmia Jain (Jind State) Charity Trust, Delhi.

(4) Income-tax Reference No. 43 of 1965. The Commissioner of Income-tax v. Bhriguraj Charity Trust, Delhi.

(5) Income-tax Reference No. 37 of 1965. The Commissioner of Income-tax v. Dalmia Jain Charity Trust, Delhi.

(6) Income-tax Reference No. 38 of 1965. The Commissioner of Income-tax v. Dalmia Jain Charity Trust, New Delhi.

( 2 ) THE respondent-trusts were created by Seth Ramkrishna Dalmia. The first four trusts were created as per trust-deeds dated April 12, 1948, March 7, 1949, June 14, 1948 and March 9, 1949 respectively. The Trust which is the subject matter of 5th and 6th References, was created as per trust-deed dated June 1, 1946.

THE following question