Judgment

HIDAYATULLAH, J. : These seven appeals have been filed on a certificate granted by the High Court of Bombay against the judgment and order of the High Court dated October 8, 1958, in a case referred by the Income-tax Appellate Tribunal, Bombay.

2. The first appellant is the Bhor Industries, Ltd., a Company incorporated in 1944 in the former Bhor State with its registered office also situated in the town of Bhor. It did the business of dyeing, printing and bleaching cloth, cloth proofing, etc., in Bhor State. The remaining five appellants are the shareholders of this Company, which, admittedly, was a private Company limited by shares, at all material times. We are concerned in these appeals with the account years of the Company, 1946 and 1947. During these years, the income of the Company was as follows :-

Assessment year Total Income Income accruing or arising in the Indian State of Bhor Total World Income (Sum of 2 & 3)

1 2 3 4

1947-48 Rs. 4,32,542 Rs. 2,24,542 Rs. 6,57,084

1948-49 Rs. 4,32,709 Rs. 3,47,416 Rs. 7,80,125

3. The Company held its general meetings to declare dividends, at Bhor on August 17, 1947 and August 19, 1948 respectively. For the account years 1946 and 1947