G. Kumara Pillai, J.

1. This is a reference made by the Commissioner of Agricultural Income Tax (Board of Revenue), Kerala, under S.60 of the Travancore Cochin Agricultural Income Tax Act, 22 of 1950, and it relates to the assessment of one A. S. Suppan Chettiar, Pankajam House, Bodinayakanoor, for the years 1951-52 and 1952-53 under the said Act. For the four years 1951-52, 1952-53, 1953-54 and 1954-55 he was assessed to agricultural income tax by an order of the Inspecting Assistant Commissioner, Kottayam, dated 31-1-1955. Out of the four assessments made by that order, two, namely, the assessments for 1951-52 and 1952-53, were interfered with in revision under S.34 of the Act by the Commissioner of Agricultural Income Tax in 1957, and that interference has caused the application for this reference.

2. The accounting period for the assessments of 1951-52 and 1952-53 were the years ending 31-3-1951 and 31-3-1952. Prior to these accounting periods Suppan Chettiar had transferred some properties belonging to him in favour of two of his sons, Natarajan and Mohan, who were minors on the date of the transfer and also during the accounting periods for the four assessments. On acco