(1.) IN this reference at the instance of the revenue, the following question has been referred for our opinion in respect of the assessment year 1980 -81 :
(2.) THE assessee claimed before the Income Tax Officer that a partial partition had taken place amongst the members of the Hindu undivided family on 3 -3 -1979. It was stated that a sum of Rs. 50,000 standing to the credit of the Hindu undivided family in the bank account had been divided between the coparceners as under :
(3.) WE have heard, Mr. B.B. Naik, the learned counsel for the revenue and Mr. K.H. Kaji, the learned counsel for the respondent -assessee.