1. This is a reference under section 66(1) of the Indian Income-tax Act, 1922, which will be hereinafter referred to as the Act.

2. The question of law referred for the opinion of this court is : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that registration should be granted to the firm." The facts material for the purpose of this case may be stated thus : One Seshmull was the son of Roopchand; they were the only two members of their family; the father and the son got divided some time prior to November 15, 1936; on November 16, 1936, they entered into a partnership to carry on the very business that their family was carrying on earlier; Seshmull died on September 15, 1955, leaving behind him his widow Anoop Kunwar; he had no children; Roopchand died on November 29, 1955, leaving behind him his widow, Gattu Bai; after the death of Roopchand, Gattu Bai and Anoop Kunwar entered into a partnership; that firm was registered under section 26A of the Act; on October 17, 1956, Anoop Kunwar adopted Jugraj as a son to her deceased husband; the Hindu Succession Act came into force on June 17, 1956; Gattu Bai died on August 9, 1959; o