Judgment

AYYANGAR, J. : These four appeals are pursuant to certificates granted by the High Court of Bombay under Art 133(1)(c) of the Constitution and raise identical questions for consideration.

2. The respondents in these four appeals are each of the four partners in a firm constituted under the name of Mafatlal Gagalbhai & Sons and which was composed of Navinchandra Mafatlal, Arvind N. Mafatlal, Yoginder N. Mafatlal and Hemant Mafatlal with share of 5/16, 3/16, 3/16 and 5/16 respectively in that firm (It has to be mentioned that Navinchandra died subsequent to the decision of the High Court and his legal representatives have been brought on record in Civil Appeal No. 502 of 1959 but this circumstance being irrelevant we are ignoring it for the purposes of these appeals). The firm was registered under the Indian Income-tax Act. There was a private limited company named Mafatlal Apte and Kantilal Limited registered under the Phaltan State Companies Act. Ten shares in this private company stood in the name of Navin Chandra, 10 in the name of Arvind and 20 in the name of Hemant. For the account year of the company ending September 30, 1945, the company disclosed a net profit of Rs. 1