Dipak Kumar Sen, J. - (1.) Satya Dulal Singha, the assessee, had been carrying on business in partnership with his brother, Satya Gopal Singha, till May 21, 1971.
(2.) While in partnership, the assessee and his brother transferred Rs. 40,000 each, aggregating Rs. 80,000, to their widowed mother and their unmarried sisters. The said amount was, however, retained by the partnership.
(3.) On May 21, 1971, Satya Gopal Singha, the brother of the assessee, retired from the firm, the firm was dissolved and the business of the firm was taken over by the assessee as the sole proprietor. The said sum of Rs. 80,000 remained deposited in the business.;