Commissioner of Income Tax vs Humayun Raza and Another

The facts of this case are simple and are fully set out in the statement of the case by the Commissioner of Income Tax. In our opinion it is not necessary to say more than that we entirely agree with the judgment of the Full Bench of the Lahore High Court in Umar Baksh v. The Commissioner of Income Tax, Punjab 1931 Lah 578 to the effect that the proper construction of the words "religious and charitable purposes" in the Income Tax Act is to be judged not by the personal law of the assesses but according to the general principles of construction applying to statutes. Accordingly we uphold the view of the Commissioner of Income Tax. The assessees have failed and they must pay Rs. 200 as costs of this Court in addition to the amount held in deposit.