COMMISSIONER OF INCOME TAX Vs. NANDINIBEN NAROTTAMDAS

JUDGEMENT

(1.) THE Tribunal has referred the following three questions of law for the opinion of this Court For the asst. year 1967 68

(2.) THREE assessment years are involved herein, as indicated by the questions themselves. They are asst. yrs. 1967 68, 1968 69 and 1969 70. The corresponding previous years are Samvat years 2022, 2023 and 2024, respectively.

(3.) THE declaration went on to state further that the assessee held 0 1 0 share in the said firm in the capacity of trustee of the said trust and not in the capacity of the owner of the same. By another declaration made on May 4, 1967, more or less in similar terms, the assessee made a similar donation of her 8 paise share in the firm of Star Radio and Electric Co. for the benefit of the beneficiaries named in the same trust. The said declaration also went on to state that the assessee held her share in the said partnership firm in the capacity of trustee of the said trust and not in the capacity of the partner of the same.