( 1 ) THE points involved in this Reference are a little out of the common and have afforded some relief from the dreariness of the ordinary Income-tax Reference. The most interesting of the points raised by Dr. Pal had, however, to be ruled out, as it did not seem to us to arise out of the appellate order. Also, of the three questions referred, two were ultimately abandoned as it was conceded that, on the materials on record, they could not be answered.

( 2 ) THE assessee is one Kumar Jagadish Chandra Sinha, who is an individual resident and ordinarily resident in India. He owns a zemindary situated wholly in the district of Jessore which, as a result of the Partition, went to Pakistan with effect from 15-8-1947. The assessee observes the Bengali Calendar year in maintaining his accounts. In the accounting year 1354 B. S. , corresponding to 14-4-1947, to the 13-4-1948, the assessee received from his zemindary in Jessore an income of 1,85,380/ -. It is not disputed that the money was rent derived from land used for agricultural purposes, but it was Income of a period, during a part of which the land belonged to undivided India and during the remaining part it