1. In this case the assessee is a Hindu undivided family. The assessment relates to the assessment years 1949-50 and 1950-51, the relevant accounting years being Sambat 2004-05 and 2005-06. Janki Sao is the Karta of the Hindu undivided family. Ho has two sons, Lakhanlal and Punulal. The business of the Hindu undivided family was the manufacture of gold and silver ornaments. It was found by the taxing authorities that on the llth of February, 1948, a sum of Rs. 18,000.00 was advanced on usufructuary mortgage of a house. On the 29th of June, 1949, the same property was purchased by Punulal for a sum of Rs. 29,500/-. A part of the consideration was the satisfaction of the mortgage debt and the balance of the amount, namely, Rs. 11,500.00 was paid in cash.

Both the documents, namely, the usufructuary mortgage bond dated the llth of February, 1948, and the sale-deed dated the 29th of June, 1949, were in the name of Punulal. On the 29th of June, 1949, there was an agreement between all the members of the Hindu joint family to the effect that the house property was really purchased by Punulal and the Hindu joint family had nothing to do with it. On the 1st of July, 1949, Janki Sao