MALIK, CJ. :- This is a reference under S. 66(1), Income-tax Act, made on behalf of the Commissioner of Income-tax against an order made by the Tribunal that the assessee was entitled to exemption under certain provisions of S. 4(3), Income-tax Act.

2. The assessee is the Dayalbagh Satsang Sabha (hereafter called the Sabha in this judgment). This Sabha is a body registered under the Charitable Societies Registration Act (Act No. 21 of 1860).

3. It may be necessary here to mention that in the year 1861 a new faith or religion was founded by Swami Shiv Dayal Singh, the followers of which were known as Satsangis to which Hindus, Mohamedans, Parsis or Christians could be initiated provided they were found to be fit and suitable by the spiritual head. The object of the religion, as described by their Lordships of the Judicial Committee in - Chhotabhai v. Janan Chandra, AIR 1935 PC 97 at p. 99 (A) was to attain true and perfect salvation by the liberation of the spirit from the bondage of mind and matter which can only be achieved by following the practices prescribed by the religion.

The history of the growth of this new religion is described in the judgment of their lordship, of