Judgment

P. JAGANMOHAN REDDY, J.:- These two Appeals are by Special Leave against the Judgment of the Punjab and Haryana High Court answering the Reference under Section 66 (1) of the Indian Income-tax Act, 1922 (hereinafter referred to as the Act ) against the assessee the Appellant. The Appellant who was admittedly a Ruler of the erstwhile Faridkot State challenged the assessments made against him for the years 1946-47 and 1947-48 with respect to which the accounting years were Vikram year 2002 and 2003 corresponding to the period 13th April 1945 to 12th April 1946, and 13th April 1946 to 12th April 1947 respectively. The assessment in each of these years was made under Section 34 read with Section 23 of the Act, as the assessee s income from dividends and interest and capital gains earned by the assessee during the relevant accounting year in what was then British India had not been brought to tax. The assessee objected to these proceedings and contended before the Income-tax Officer that he being a Ruler of the Faridkot State was immune from taxation on every source of income. He could not therefore, by virtue of his sovereignty be treated as an assessee for any purpose under t