JAGADISAN J.

The question referred under section 66 of the Indian Income-tax Act is " whether the income derived by the assessee-trust from business is exempt from tax under the provisions of section 4(3)(i) of the Act for the assessment years, 1952-53 to 1955-56 ? " The assessee is a religious and charitable trust called. " Thiagesar Dharma Vanikam ". It was founded by one Karumuthu Thiagarajan Chettiar under a deed of trust dated May 13, 1948. The founder furnished the trust with a sum of Rs. 61, 000 as a nucleus fund to be augmented and utilised for the purpose of the trust set out in the deed. A business in cotton yarn and cloth was started by the board of trustees or the managing trustee of the said trust with the help of this sum of Rs. 61, 000. Even during the first year of business a net profit of Rs. 5, 94, 493 was earned and this was added to the capital account. In the next year, 1949-1950, a profit of Rs. 85, 105 accrued and this was also capitalised. During the year ended June 30, 1951, the previous year for the assessment year 1952-1953, the trust acquired a printing press and carried on business as printers. For the years ended June 30, 1951, to June 30, 1