( 1 ) THIS is a Reference under sec. 66 (1) of the Indian Income Tax Act 1922 at the instance of the assessee. The assessee in this case is Keshavlal Lallubhai Patel an individual. The relevant year of assessment is 1952-53 the relevant accounting period being 1/04/1951 to 31/03/1952. The assessee has a wife by name Revagauri an adult son by name Navinchandra and a minor son by name Hasmukhlal. The assessee and the members of his family had been assessed as individuals for a number of years past. The assessee his wife and two sons were members of a Hindu undivided family. As stated by the Income Tax Officer there was however no coparcenary property. The assessee was possessed of self-acquired properties. On 18/04/1951 the assessee threw some of his self-acquired properties consisting of agricultural lands a house and shares of limited liability companies into what is stated to be the common hotchpot of the said Hindu undivided family. This is evidenced by an affidavit sworn by the assessee on 18/04/1951. No entries in the books were made evidencing such a transaction. No transfers were effected at or about that time. On 18/06/1951 an oral partition was effected among