Judgment

S. K. Das, J. : These two appeals with special leave have been heard together. They arise out of similar facts and the question of law arising therefrom is the same.

2. The short facts are these. One Balkrishna Purshottam Purani died on November 11, 1947. He left behind him three widows and two daughters. The three widows were named Indira, Ramluxmi and Prabhuluxmi. These widows as legal heirs inherited the estate of the deceased, which consisted of immovable properties situate in Ahmedabad, shares in Joint Stock Companies, money lying in deposit, and share in a registered firm. For the two assessment years 1950-51 and 1951-52 (the corresponding account years being the Sambat years 2005 and 2006) the Income-tax Officer issued notices to the legal heirs of Balkrishna Purushottam Purani. Pursuant to those notices, returns were filed under the heading. "Legal heirs of Balkrishna Purushottam Purani", in one case and in the name of the estate of Balkrishna in the other; the status was shown as "individual" in one case and "association of persons" in the other. They were signed by Indira, one of the three widows. For the assessment year 1950-51 the total income was shown as under-