BACHA F GUZDAR BOMBAY Vs. COMMISSIONER OF INCOME TAX BOMBAY

JUDGEMENT

(1.) This appeal raises an interesting point of law under the Indian Income-Tax Act.

(2.) The question referred by the Tribunal to the High Court of Judicature at Bombay was stated thus:

(3.) The facts lie within a narrow compass. The appellant, Mrs. Bacha F. Guzdar, was, in the accounting year 1949-50, a shareholder in two Tea companies, Patrakola Tea Company Ltd., and Bishnauth Tea Company Ltd., and received from the aforesaid companies dividends aggregating to Rs. 2,750/- The two companies carried on business of growing and manufacturing tea. By Rule 24 of the Indian Income-Tax Rules, 1922, made in exercise of the powers conferred by Section 59 of the Indian Income-Tax Act, it is provided that