Judgment

SHAH, J. : One S. K. Mohideen - hereinafter referred to as the assessee - was a partner in two firms - Messrs. Dinshaw and Co. and Messrs. Palaniappa Chettiar and Co. The firms were registered under the Indian Income-tax Act. The assessee submitted returns of his income and incorporated therein the estimated share of his losses in the two firms at Rs. 20,000/- and Rs. 10,000/-, for the assessment year 1946-47 and at Rs. nil and Rs. 12,436/- for the assessment year 1947-48. The Income-tax Officer, V Circle, Madras, completed the assessment for the two years on February 20, 1950 after adopting the estimates furnished by the assessee, but he made a note that the losses accepted were subject to revision on ascertainment of correct particulars. The assessment of Messrs. Dinshaw & Co. for the years 1946-47 and 1947-48 was completed on October 31, 1950 by the Income-tax Officer, II Circle, Madras and the proportionate share of the assessee for the losses was computed for the two years at Rs. 15,839/- and Rs. 1,046/- respectively. Assessment of Messrs. Palaniappa Chettiar & Co. for 1947-48 was completed by the Income-tax Officer, Special Circle, on June 30, 1951 and the share of th