JUDGMENT

RAMASWAMI J.-The question for consideration in these appeals is Whether the respondent, a Hindu undivided family, is entitled to exemption from taxation in respect of the interest income from Government securities held by it, under a notification of the Government of India dated March 21, 1922, issued under section 60 of the Income-tax Act, 1922.

The late Raja of Bhor held certain Government securities and up to the assessment year 1953-54, he was assessed in the status of individual in respect of his income. He died on October 9, 1954. His estate including the Government securities thereupon passed to his three sons who constituted a Hindu undivided family. The eldest of them succeeded to the title of Raja of Bhor. For the assessment years 1954-55 to 1958-59 the present Raja of Bhor filed returns as a Hindu undivided family consisting of himself and of his two brothers. He claimed exemption in respect of the interest income with regard to the Government securities on the ground that it was exempt under the notification issued under section 60 of the Income-tax Act, 1922. Section 60 empowers the Central Government, by notification in the Official Gazette, to make exemption,