( 1 ) THE petitioners Nos. 3 to 7 along with Kantilal Jivanlal Shah and Manganlal Chhaganlal Shah, both since deceased, were partners of M. Ambica Cold Storage, a partnership firm constituted on the 23rd April, 1958, and registered under the Indian Partnership Act. The firm has since been dissolved. The case of the petitioners is that the firm commenced business in the middle of February, 1959, and was for the first time assessable and assessed to income-tax for the assessment year 1960-61. The accounting period of the firm was the English calendar year ending on the 31st December of each such year and under the deed of partnership the first accounting period for completion of the accounts of the firm was 31st December, 1959. On the 25th July, 1958, the firm purchased 3 bighas 7 cottahs 5 chittaks more or less of land at Sheoraphully for Rs. 19,857. 19, and on the 25th April, 1961, it purchased further 1 bigha 5 cottahs 7 chittacks of adjacent land for Rs. 10,225. Although the land was first purchased in July, 1958, as the negotiations for the purchase were completed by May, 1958, the purchase of materials for construction as well as the work of construction of