Judgement

SHAH, J.:- The assessee -M/s. A. Raman and Company-are dealers in "mill stores". In the course of their business they sell "mill stores" to other dealers including two concerns trading in the names of M/s. A. M. Shah and Co. and M/s. R. Ambalal and Co., which are owned by the Hindu undivided families, managers of which are the only partners of the assessees. For the assessment years 1959-60, 1960-61 and 1961-62 the assessees were originally assessed by the Income-tax Officer, Circle-I, Ward-A, Ahmedabad, while the partners of the assessees and the Hindu undivided families which traded in the names of M/s. A. M. Shah and Co. and M/s. R. Ambalal and Co. were assessed by Income-tax Officers in other Circles. The cases of the assessees, of the partners of the assessees and of the two Hindu undivided families trading in the names of A. M. Shah and Co. and R. Ambalal and Co. were later transferred to the Income-tax Officer, Group Circle-J, Ahmedabad. That Officer by letter dated March 20, l964 informed the assessees that he was convinced from a perusal of the assessment records of the assessees, their partners and their individual Hindu undivided families that the partners of th