Kamla Sahai, J.

1. In this case, the assesses is a Hindu undivided family consisting of M. L. Rungta (Mangilal Rungta) and his sons. Three of those sons are M. G. Rungta (Madan Gopal Rungta), B. N. Rungta) (Biswanath Rungta) and S. R. Rungta (Sitaram Rungta). The questions which arise for decision in this case relate to the income from Jugasalai Electric Supply. Co. The assessees case is that shares are held in the Electric Supply Co. as follows:

M.L. Rungta (as representing the Hindu undivided family)....as. -/4/-

M. G. Rungta.... -/4/-

B. N. Rungta.... -/4/-

S. R. Rungta.... -/2/-

An Outsider....as. -/2/-

2. The assessment years in question are 1945-46, 1946-47, 1947-48 and 1948-49. But the assessment in respect of each of the assessment years does not have to be separately considered because the point involved is the same. The Income-tax Officer held that the shares allotted to M. G. Rungta, B. N. Rungta and S. R. Rungta in the Jugasalai Electric Supply Co. were all held by the Hindu undivided family in their names, as the funds said to have been contributed by these coparceners of the family to the Electric Supply Co. were the funds of the Hindu undivided family. The as