CHAKRAVARTTI, J.

1. THESE are nine references concerning as many assessments of 8 ladies for, in the case of all of them, the asst. yr. 1945-46, and in the case of one, for the asst. yr. 1946-47 as well. The point involved in all these cases is the same. The question asked is whether a particular sum of money, which was the profit made by the lady concerned from the sale of a block of shares held by her, was a part of her business income, taxable as such or a casual receipt from a source other than business and so exempt from taxation.

2. THE proceedings have had a course which, for income-tax cases, is rather unusual. In the Tribunal there was a difference of opinion between the two members, the Lawyer Member holding that the amounts concerned were not taxable and the Accountant Member holding that they were. Thereupon the cases were referred to a third member who happened to be an accountant and he agreed with the Accountant Member for the reasons given by him. THE judgment of the Tribunal must therefore, be taken to be the judgment of the Accountant Member.

It is impossible not to remark on the form in which the references have been made. In reality, the Tribunal has subm