PATEL B R Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) WE had directed the Income-tax Appellate Tribunal to state a case on the following question, viz., whether the inclusion of the entire interest credited in the account books of Cine Supplies Private Ltd., Bangalore, in the joint loan account of M/s. B. R. Patel, I. A. Patel and H. R. Patel in the assessments of the assessee is legal

(2.) BEFORE us, Mr. Ramarao, learned counsel for the assessee, contends vehemently that the principle of double taxation has been contravened and the assessments on B. R. Patel, the assessee, is illegal. While th principle of law is clear, namely, that no income can be chargeable twice in the hands of the same individual or in the hands of different individuals, the question before us is whether there was in fact evidence to support the contention of the assessee that there was in fact double taxation.