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Issues:
Whether the pension received by the assessee from the United Nations World Health Organisation is exempt from tax. Analysis: The main issue in these appeals is whether the pension received by the assessee from the United Nations World Health Organisation is exempt from tax. The assessee, a former employee of the United Nations, claimed that the pension amounts received during the relevant assessment years should be exempt from taxation under the United Nations (Privileges and Immunities) Act, 1947. The Income Tax Officer (ITO) rejected this claim, arguing that the exemption only applied to salaries of officials and not to pensions. Consequently, demands were made for compulsory deposits under the Income-tax Payers Act of 1974. The assessee appealed these orders before the Appellate Assistant Commissioner (AAC) of Income Tax, who ruled in favor of the assessee based on previous decisions and the interpretation of the law. The Department's representative contended that the exemption under the United Nations Act was applicable only to officials of the organization and not to retirees. The Department argued that the pension should be considered part of the salary and therefore taxable. However, the assessee's counsel relied on previous decisions by the AAC and the Tribunal, which held that pension receipts for the same assessee in earlier years were exempt from tax. The Tribunal considered the interpretation of the law, specifically the definition of 'salary' under the Income Tax Act, which includes pension. The Tribunal agreed with the AAC's finding that the pensions received by the assessee should not be taxed. As a result of this decision, there was no further demand for compulsory deposits, as the taxed amounts had already been paid by the assessee. The Tribunal dismissed all six appeals by the Department, upholding the decision that the pension received by the assessee from the United Nations World Health Organisation was exempt from tax.
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