SOOL CHAND RAM SEWAK Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THIS consolidated reference made by the Appellate Tribunal under Section 66(1) of the Indian Income-tax Act, 1922, arises out of three assessments relating to the assessment years 1951-52, 1952-53 and 1953-54. The facts are as follows :

(2.) THE Income-tax Officer who did not accept the claim of partition of the family took no action whatever on these returns and he included the income returned by the firm in the assessments of the Hindu undivided family for the said assessment years.

(3.) THE assessee appealed to the Appellate Assistant Commissioner. THE Appellate Assistant Commissioner held that the assessments were time-barred and invalid and he vacated the assessments by his order dated the 25th August, 1959.