Hence these appeals.
The interest realised and the dividends earned were included in the income of Karam Chand Thapar for the purpose of assessment in the assessment years mentioned earlier.
The assessment years with which we are companycerned in these appeals are 1949 50, 1950 51, 1951 52, 1952 53 and 1953 54.
Appeals from the judgments and order dated July 30, 1963 and February 11, 1965 of the Calcutta High Court in Income tax Reference No.
Mohini Devi Thapar was income from assets directly or indirectly transferred by the assessee to his wife within the meaning of Section 16 3 of the Income tax Act.
The assessee objected to the inclusion of that amount in his income.
Hence I income arising to the three minor sons of the assessee by virtue of their admission to the benefits of partnership in the firm companyld number 1 1970 77 I.T.R. p. 27.
48 of 1959, and 69 of 1961 respectively.
The question is whether the department was entitled to include the dividends and interest in question in companyputing the taxable income.
Pal, T. A. Ramachandran and D. N. Gupta, for the appel lants and respondents Nos.
The Judgment of the Court was delivered by Hegde, J. All these appeals by certificate are filed by the legal representatives of Late Karam Chand Thapar who was the assessee in this case.
CIVIL APPELLATE JURISDICTION Civil Appeals Nos.
21,225 derived from deposits and shares held by the assessees wife, Smt.
The Income tax Officer held that they were liable to be included in the income of the assessee.
C. Manchanda, P. L. Juneja, R. N. Sachthey and B. D. Sharma, for respondent No.
Similar questions were referred in respect of other assessment year.
of the assessee.
That decision was upheld by the Appellate Assistant Commissioner.
1374 and 2146 to 2149 of 1970.
2 to 4 in all the appeals .
On a further appeal, taken by the assessee to the Tribunal the Tribunal upheld the order of the Assistant Commissioner.
1 in all the appeals .
He died after the assessments were made.
Thereafter at the instance of the assessee, the question set out below was submitted to the High Court under section 66 1 of the Indian Income tax Act, 1922, in respect of the assessment year 1949 50 Whether on the facts and on the circums tances of the case, the income of Rs.
