ORDER

1. Assessees are the appellants. They are aggrieved by the judgment of the Andhra Pradesh High Court answering the question referred to it under Section 256(1) of the Income Tax Act, at the instance of the Revenue, against them. The two questions referred read as follows :

"(1) Whether on the facts and circumstances of the case the profits of Rs 41,666 derived by the assessee was an adventure in the nature of trade;

(2) If the answer to the above question is in affirmative, whether the assessment could be made in the status of an association of persons."

2. The assessees are the wives of two brothers, who are partners in a firm. In December 1963, the assessees purchased a piece of land measuring 8479 sq. yards in the Banjara Hills area of Hyderabad, for a consideration of Rs 10,620. They say, they raised the purchase-money by selling their silver to the partnership firm, of which their respective husbands are partners. The firm deals in bullion. Shortly after purchasing the land, they carved it into four plots and sold them individually. Two agreements of sale were entered into, one in May and the other in July 1964 and sale deeds executed in pursuance thereof on October 9, 1964