COMMISSIONER OF INCOME TAX Vs. JUGAL KISHORE BALDEO SAHAI

JUDGEMENT

(1.) THIS is an income-tax reference under section 66(1) of the Income-tax Act. The question which has been referred to us for opinion is :

(2.) THE assessee was a Hindu undivided family carrying on an ancestral business in the name of Jugal Kishore Baldeo Sahai. THE business was of commission agency in cloth. THE family also derived income from property and was a partner through its karta (Babu Ram) in several firms. THE share of profit from these firms also formed part of the income of the assessee.

(3.) THE assessee went up in appeal to the Appellate Assistant Commissioner of Income-tax, who upheld the Income-tax Officer and made the following points :