COMMISSIONER OF INCOME Vs. SHRI GIRDHARRAM HARIRAM BHAGAT
HIGH COURT OF GUJARAT
COMMISSIONER OF INCOME
Shri Girdharram Hariram Bhagat
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(1.) B.K. Mehta 1. Since the judgment of the court was delivered by MEHTA J.-Since the questions referred to us at the instance of the Commissioner of Income-tax, Gujarat, and the rival contentions urged in connection therewith are common and identical in both these references, we propose to answer the questions referred to us by this common judgment.
(2.) In Income-tax Reference No. 214 of 1978, we are concerned with the assessment years 1967-68, 1968-69 and 1969-70, while in Income-tax Reference No. 68 of 1977, we are concerned with the assessment years 1970-71 and 1971-72.
(3.) The necessary and relevant facts leading to these two references may be briefly stated as under: The assessee is an individual and is a direct descendant of one well-known and renowned saint in Saurashtra area in particular and Gujarat in general, known and fondly called as Jalarambapa. The assessee is the son of Hariram, who was the daughter's son's son of the said Jalarambapa and was adopted by him. It is claimed that Jalarambapa was a person of saintly disposition right from his young age, and he engaged himself in the recitation of Ram Nam. In his temporal life, he devoted himself to the service of saints and sadhus. He was an agriculturist, but the service of feeding sadhus, pilgrims and the poor became a dominant passion of his life.;
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