Judgment

GROVER, J.: This is an appeal by certificate from a judgment of the Calcutta High Court in an Income-tax Reference.

2. The assessee during the material time was a Hindu Undivided Family consisting of the six members. In the original assessment for the assessment year 1946-47 the year of account being from April 14, 1945 to April 13, 1946, the Income-tax Officer determined the total income of the assessee at Rs. 35,741/- accruing from the business and other sources such as sale proceeds of forest produce, fisheries etc. Following demonetization of High Denomination Notes in January 1946 the assessee encashed such notes of the value of Rs. 19,000. The five members of the family named below also enacted notes of the value shown against each of them, the total value of the notes so encashed being Rs. 1,10,000:

1. Hem Chandra Kar Rs. 26,000

2. Jatindra Nath Kar Rs. 24,000

3. Atul Chandra Kar Rs. 23,000

4. Narendra Nath Kar Rs. 21,000

5. Bishnuram Kar Rs. 16,000

3. The Income-tax Officer reopened the assessments of the Hindu Undivided Family and of the five members for the assessment year 1946-47. He included Rs. 19,000 in the total income of the family and the amounts which had be