Judgment

BHAGWATI, J. : These four appeals with Special Leave granted by this Court under Article 136 of the Constitution are directed against the orders, dated the 8th June 1951, of the Income-tax Appellate Tribunal, Bombay A in Reference Applications Nos. 737, 738, 739 and 740 of 1949-50 and arise under the following circumstances :-

2. The appellants were at all material times a Hindu undivided family of which Rameshwarlal Ganeriwalla is the Karta. As a result of certain transactions which need not be detailed here Rameshwarlal Ganeriwalla became the creditor of the Nawab Bahadur of Murshidabad in a large sum of over Rs. 6,38,000 by about 1928-29. Sometime in 1933, an Act named Murshidabad Estate Administration Act, 1933 (Act XXIII of 1933) was enacted under the provisions whereof the Estate of the Nawab Bahadur was taken over by the authorized Manager. The debt due by the Nawab Bahadur to Rameshwarlal Ganeriwalla was admitted by the Board of Revenue in a sum of Rs. 5,42,173 as on 1st April 1934 and the Manager from time to time made payments by way of dividends to the appellants indicating in the covering letters how the payments were to be appropriated. The appellants for the as