COMMISSIONER OF INCOME TAX Vs. S MARIAPPAN

JUDGEMENT

(1.) THE assessee "S. Mariappan", it is said, is a partnership firm. THE said firm was stated to have been constituted with four partners. It is located at No. 444, Trichy Main Road, Sanjeevirayanpet, Salem -6. THE said partnership had been constituted with the avowed purpose of purchasing lottery tickets and sharing the profits among them in agreed proportion, in case of one of the tickets purchased winning prize in a lottery.

(2.) THE assessee -firm filed Form No. 11 before the Income -tax Officer, Circle 11(4), Salem -1, on March 31, 1982, under Section 185 of the Income tax Act, 1961 (Act No. 43 of 1961 for short "I.T. Act"), with a deed of partnership drawn on May 4, 1981, seeking registration to the firm.

(3.) THE former appeal is relatable to the refusal of grant of registration under Section 185 of the Income -tax Act and the latter is relatable to the assessment order being passed, treating the four partners of the alleged firm as "association of persons", relatable to the assessment year 1982 -83.