SETHURAMAN J.

The assessee appears to have come into existence some time in 1857. It was registered under the provisions of section 26 of the Indian Companies Act, 1913. Its objects were : (1) to provide a club for the accommodation of members and their friends and the encouragement and management of sports and games

"and (9) to promote social intercourse amongst the members of the club and their friends and encourage and manage sports and games" *

. The rest of the clauses are in the nature of ancillary clauses. Clause 11 provides that the objects of the club as set out in the earlier paragraphs would extend to all the States in the Indian Union. Clause 12 provides that the income and property of the club whensoever derived shall be applied solely towards the promotion of the objects of the club as set forth in the memorandum of association and that no portion thereof should be paid or transferred directly or indirectly by way of dividend, bonus or otherwise howsoever, by way of profit to the persons who at any time were or have been members of the club, or to any of them, or to any person claiming through any of them. The assessee could, however, pay remuneration to an