( 1 ) AT the instance of the Commissioner of Income-tax, the Income-fax Appellate Tribunal has referred for our opinion the following question of law :

"whether on the facts and in the circumstances of the case, the assessee was liable to be assessed in respect of the income for the whole year from properties at Shahdara, Palwal, Dadri and Kosi for the assessment year 1951-52 ?"

THE assessee Mr. Hans Raj Gupta is an individual whose main source of income was from his share in three firms. The matter pertains to the assessment year 1951-52, the corresponding previous year being the year ending on 31st March. 1951. The assessee owned some immovable properties at Shahdara, Palwal, Dadri and Kosi which were registered in his name. However, it is alleged that in 1950, the Shahdara property was sold by the assessee to a connected company known as M/s. Raj Enamel Works Ltd. and payment received; the properties at Palwal, Dadri and Kosi were also sold to a connected company M/s. Hans Raj Gupta and Co. Ltd. and the monies were received in July, 1950. But the properties continued to remain registered in the name of the assessee.

( 2 ) THE share-holders of M[s. Raj Enamel Works Lt