LORD -WILLIAMS, J. - (1.) THIS is a case stated by the Commissioner of Income Tax at the instance of the Calcutta Stock -Exchange Association Limited under Section 66(2) of the Income Tax Act (XI of 1922).
(2.) THE assessees are a mutual benefit liability company, their main objects being to support and protect the character, status and interest of brokers and dealers in stocks and shares on the stock exchange, to give facilities to its members to carry on business, to make rules and bye -laws to regulate business, to settle disputes amongst themselves and to maintain a stock exchange.
(3.) THE Company owns a four storeyed building at 7, Lyons Range Calcutta, on the ground floor of which there is a large hall used as the meeting place of the Stock Exchange, two tiffin rooms a telephone room and a quotation room. On the mezzanine floor are situated the offices and meeting place of the association, while the first, second and third floors are occupied by members. The rooms on these floors are let our by the Company to the members of the Stock Exchange. They are not used by them for the purpose of residence. The Company owns, in addition to this building certain securities, and derives an income from other sources, such as the publication of the Stock Exchange quotation lists which are sold both to members and to non -members of the Association.;