Dismissing the writ appeal, that the principle of diversion of income by overriding title had no application to the salary paid to nuns and priests by the Government or any other employer. The right under article 25 of the Constitution is not an absolute or an unfettered right. Article 25 does not provide any immunity from taxation on the basis of religion. If a valid law permits deduction of tax at source, such deduction does not violate the fundamental right of freedom to practice religion.The mandate of section 192 is clear that tax has to be deducted at source from the salaries payable to nuns and priests. A practice which was contrary to the law of the land, could not be permitted to be continued. It is explicit from a reading of the circular issued on December 5, 1977, that, though the caption mentions the subject as “fees of members of religious congregation”, the recital portion of the circular refers only to the fees received by missionaries in contradistinction to salary received by nuns or priests. The circular of 1977 cannot apply to salaries received by nuns or priests from the Government or aided institutions. Further, the clarification issued by the Central Board of Direct Taxes in 2016, pursuant to the direction of the court in these appeals, states in unmistakable terms that the circular does not apply to salaries and pensions received by nuns or priests. The 1944 circular or even the 1977 circular cannot be construed as excluding tax deducted at source from the salaries received by nuns and priests from their respective establishments. Salaries paid to nuns and priests, who are employees of educational institutions, are liable for tax deduction at source.