BHAGWATI, J. :- This Reference raises two questions relating to the assessment of the assessee who is the Acharya, that is, spiritual preceptor of one of the two dioceses of the religious denomination known as Swaminarayan Sampradaya. In order to be able to arrive at a proper determination of these questions, it is necessary to go a little into the history of this Sampradaya culminating in the framing of the Scheme by the High Court in Appeal No. 430 of 1927. The entire history is set out in the judgment of the High Court in that appeal and that judgment having been referred to and relied upon in the order of the Tribunal, a copy of it has been taken on record by us by consent of parties. The whole of the history is however not material and we will, therefore, state only so much of it as is necessary for the purpose of the present Reference.

2. This Sampradaya which has a large number of adherents in this part of the country was founded by a great Hindu religious reformer named Sahajanand Swami who came to Gujarat in the early part of the nineteenth century. Himself of a life of religious austerity, he fiercely denounced the licence and immorality prevalent among the priest