Judgement

P. B. GAJENDBAGADKAR, J. : These are appeals by special leave and they arise from the assessment proceedings taken against the appellants husband Seth Ganga Sagar Jatia in respect of his income for the assessment years 1943-44 and 1944-45. The said Seth Ganga Sagar died on September 22, 1944, leaving behind him his widow the appellant Shrimati Indermani Jatia. After the death of her husband, the appellant continued the assessment proceedings as his representative and administrator of his estate.The appellant as well as her husband were residents and ordinarily residents in British India for the relevant years. The sources of the assessee s income for the purposes of income-tax assessment were his business, his house property and the dividends earned by him. This business was carried on by the appellant after his death at Khurja and Aligarh which are part of India and at Chistian in the Indian State of Bahawalpur now a part of Pakistan. The central set of accounts of the assessee s business were kept at Khurja. In this set of accounts income received by the assessee from all sources were incorporated. For the accounting year relevant to 1943-44 assessment, the interest acco