( 1 ) THE assessee is a planter and owner of coffee estates. He is one of three brothers between whom there was a partition on the 10th of May, 1938, by which the ancestral property was divided equally amongst them after due provision had been made for the female members. His family constitutes his wife and two daughters. Till the assessment year 1960-81, now in. question, the assessee returned and was assessed in the status of an individual, but then he claims his status was that of a Hindu undivided family. The Wealth Tax Officer wrote:

"on verification, it is seen that in the past the assessment has been made in the status of an individual only. No information has been adduced to show the status as that of the Hindu undivided family. The assessee has got absolute right over the properties as an individual and there is no other male member who could claim right over the properties and partition of the same. Hence the status is held as that of an Individual as in the past. "

The assessee also contended before Wealth Tax Officer that a sum of Rs. 85,000/- provided as a liability for taxation should be allowed. The Wealth Tax Officer wrote:

"on examination of the cla