--- ------'586 SUPREME COURT REPORTS {1974] 2 s.c.n. in the felicitous observation made in the work already cited. 'Perhaps the oldest of all juristic persons is the God, her or the saint." In Pramatha Nath i'.fullif'k l'. Pracl)'lmma Kumar Mullick ( 1925 LR :52 lA 245 ; AIR 1925 PC 139) the Privy Council observed ; "A Hindi idol is, according to long established authority founded upon the religious customs of the Hindus, and u the recognition thereof by courts of law, a 'juristic entity'. It has a juridical status with the power of suing and being sued. Its interests arc attended to by the person who has the deity in his charge and \ho is in law its manager v.ith ;ll the powers \hich would, in such circumstances, on analogy, be given to the manager of the estate or an infant ., heir. It is unnecessary to quote the authorities ; fnr this c doctrine, thus simply stated, is firmly cstab!ishcd." The authorities thus amply est;tblish that a Hindu deity is a juristic - rson capable of holding property. Reference was made to the decision in C. l. T. v. Alrmeclabad .\fill ..()u·ners' A.uocialian (7 ITR 369) v.hcrc Beaumont, C. J. held : D "Individual" where Iirt used, must mean human being, bcausc it is used as something distinct from a joint family. firm and company. The whole expression seems to me to mean "every human being, Hindu undivided family, company, firm and other association of huma n beings." E Though in consequence of this decision the Income-tax (Amendment) Act, 1939 amended the words "assoc.:iation of individuals" into "association of persons". the word "individual" being first of the six assess.able units mentioned in section 3 was retained and w:ts not amended into "person". It could not be changed into "person" for the obvious ·reason that the 1\ord "person" is of wider import and includes any company or association or body of individuals, whether incorporated F or not. So a word had to be chosc11, \ hich \•ould not carry with it the wider import of the word "person" nod the \Ord "individual" appears to ha'e been chosen. In Cor~~missioner or Income-tax v. Sodra lJl'l'l (32 ITR 615) it was pointed out that the word "individual'' not -only means a human being but also includes a corporation created by a statute. e. g. a University, or a Bar Council or th~ trustees or a Daronctcy trust, im;(lrporatcu by a Baronetcy Act (See the decisions ·in CorrmriSJiorru of lrrcoure-ta:r; v. Salt!m District Urball .Bank Ud. 8 ITR :69 : COI!IIIIissiorr('r of Income-tax v. n., Cormfi~. 12 ITR 1 : and Str CurrlmiJIJoy Ebrahim Baronetcy Trust v. Comnu· .sslom•r of IJJcorrrt'·tux, S lTC 44), Gut Dass J, obo;erved : · " .. :· ... there is no dillic uhy \1 lwtsoewr in my opinion, in g•vJng the word 'individual' its natural meaning, that is, tl that the word means citbcr a male or a fcnwlc." llut the co.;t in !hat :~Sc was not cor1ccrned with the probl.:m ~cthr the word mdtvtdual c;tn refer to a juridical entity. Mukharjt J. of
