SHAH, J. : This Reference substantially deals with two assessments. One part of the reference concerns the assessment year 1944-45 in which 11 assessees are interested and the other part concerns the assessment year 1943-44 in which the assessee Onkarmal Meghraj is interested. We are at this stage primarily concerned with the assessment of the following 11 assessees :

1. Narayandas Pokermal.

2. Govindram (s/o No. 1).

3. Bhagwandas (s/o. No. 1).

4. Vasudeo (s/o. No. 1).

5. Meghraj Pokermal

6. Onkarmal Meghraj (s/o No. 5).

7. Banarisilal (s/o No. 5).

8. Beniprasad (s/o No. 5).

9. Hanumandas Sewakram

10. Kedarnath (s/o. -No. 9).

11. Durgaprasad (s/o. No. 9).

Sixteen persons entered on 19-5-1930 into an agreement of partnership to conduct a business in partnership in the name of Messrs. Narayandas Kedarnath. Amongst these sixteen persons there were three sets of persons who constituted Hindu United Families. Narayandas Pokermal and his three sons Govindram. Bhagwandas and Vasudeo - constituted one Hindu United Family : Meghraj Pokermal and his three sons - Onkarmal, Banarasilal and Beniprasad constituted another Hindu United

Family and Hanumandas Sewakram and his four sons - Kedarnath, Ban