COMMISSIONER OF INCOME TAX WEST BENGAL IN ALL APPEALS Vs. CALCUTTA HOSPITAL AND NURSING HOME BENEFITS ASSOCIATION LTD

JUDGEMENT

(1.) These appeals by certificate granted by the High Court of Calcutta under S. 66A(2) of the Income Tax Act, 1922, are directed against the judgment of the said High Court answering two questions referred to it against the Revenue, The questions are:

(2.) The relevant facts and circumstances are as follows:The respondent, the Calcutta Hospital and Nursing Home Benefits Association Limited, hereinafter referred to as the assessee, is a mutual insurance concern carrying on miscellanous insurance business. The principal objects for which the Association was established were:

(3.) The members were required to pay a monthly premium, but there was a waiting period of four months for all benefits other than maternity, for which the waiting period was one year. Benefits and privileges became available as from the first day of the fifth calendar month of registration (in respect of Maternity the 13th month) and continued to be available thereafter so long as the subscriptions were not in arrear.