All these appeals rotate round the identical issues. For the sake of convenience, these are consolidated and disposed of together by a common order.

2. The first issue relates to the question of ‘status what is the status of assesee ? whether the assessee trust in the acts of the case could be treated as Artificial Juridical Person ?

3. I have heard the rival submissions. The concept ‘person’ focuses large numbers of sacred relations but it allocates them differently in different cases. According to the noted jurist Ihering, ‘juristic person’ is but a symbol to help in effectuating the purpose of the group, it amounts to putting a bracket round the numbers in order to treat them as unit. Artificial Juridical Person is a unit of assessment. This was inserted din he Income-tax Act, 1961 (hereinafter called the Act). It wa not in 1922 Act. Then all such Juridical Persons were assessed as individuals.

4. The word Juridical Person is not defined in the Act. In a wider sense, it connotes an aggregate of property i.e., recognised by law as the subject- matter of rights and duties. It is the creation of the rules of procedure. A Hindu idol is a juridical Person capable of holding property and of being taxed through its shebaits who are entrusted with the possession and management of is property. It is treated s minor and shebait acts on its behalf as its guardian.

5. It is since qua non, for AOP that it must e one in which two or more persons join in a common purpose of common action. In the case of CIT v. Ibrahimji Hakimji [1949] 8 ITR 501 (Sind), it was held that trustees from AOP but this could not make them owners. The definition of the word ‘person’ given in the Act under section 2(31) in enumerative. The last category of the person defined in the said section is ‘every artificial juridical person, not falling within any of the preceding sub-clauses’. Therefore, if a person falls within any of the preceding sub-clauses, then it cannot be termed as Artificial Juridical Person.

6. I now proceed to examine the facts of the present case. The assessee is a Trust. Deed of the Trust was produced before me. The trust was set up for private religious objects. It is not an endowment. A Hindu may dedicate for religious or charitable objects all property which he can validly disposes of by gift or by will for the purpose of endowment. No writing is necessary to create an endowment. A trust is not required for that purpose. All that is necessary is that the religious or charitable purposes should be clearly specified and that the property intended for the endowment should be set apart or dedicated to those purposes. Even in the case of dedication to an idol, which cannot itself physically hold lands, it is not necessary to vet the lands in trustees. The mere execution of a deed, though it may purport on the face of it to dedicate property to an idol, is not enough to constitute a valid endowment.

7. In the given cases, the Trusts are created and one of the objects of the Trust is to establish a temple in the name of the deity specified in each of the Trust deed at S-228, Greater Kailash -II, Delhi - 48. This is the residential house where the settlers and trustees are residing. All the five Trusts are required to establish temples in the name of the specified deities at the same residential premises. The affairs of all these Trusts reveal a similar pattern as would be obvious from the following chart :—