Judgment

P. B. GAJENDRAGADKAR J.: This is an appeal by special leave against the decision of the High Court of Mysore holding that the document relied upon by the appellant does not create a relation of partnership between the appellant M. P. Davis and his brother P. W. Davis. It appears that prior to the assessment year 1952-53 the appellant who was the registered owner of the Kaimabetta Coffee Estate was assessed as an individual; but for the assessment year 1952-53 he claimed a change of status and pleaded that he and his brother had agreed to become partners under a partnership deed (Ex. 12) and asked for the registration of the said firm under S. 26 of the Coorg Agricultural Income-tax Act (I of 1951). According to the appellant the partnership in question has been constituted or the purposes inter alia of the joint working of the said estate as also for transacting generally the business or businesses of coffee, citrus and pepper and other businesses, as specified in the document. The relevant provisions of the Coorg Act correspond to the provisions of the Indian Income-tax Act; S. 26 of the said Act provides for the registration of firms for the purpose of the Act. The Agricu