(1.) HEARD Counsel for the parties.
(2.) THE Tribunal by order dt. 9th May, 1995 in compliance with the directions given by this Court by the judgment dt. 15th Nov., 1994, referred the following question for the opinion of this Court:
(3.) THE assessing authority, however, held that when the sole proprietary concern was converted into partnership, the individual property belonging to Smt. Stella, became an asset of the partnership, and, therefore, in law, there was a gift in respect of the said property.