(1.) THE assessees were partners in the firm--T.T. Krishnamachari and Company, which came into existence on May 1, 1957. On June 30, 1976, one of the partners retired and the firm was reconstituted.
(2.) THE four partners of the reconstituted firm executed a memorandum of agreement on October 14, 1976, as follows :
(3.) WE must therefore answer the first question referred to us in favour of the Revenue and against the assessee and the question is so answered.