1. - Both the above cases are disposed of by one single order as they arise out of the same order of the Income-tax Appellate Tribunal dated September 22, 1973.

2. Brief facts as set out in the statement of the case are that M/s. Narnauli Jewel Corporation, Jaipur (hereinafter referred to as "the assessee"), filed its return of income in respect of the assessment year 1968-69 declaring its status as a firm on July 2, 1968. According to the partnership deed which was filed along with the application for registration under section 185 of the Income-tax Act, 1961, the firm was constituted on November 14, 1967. The following persons were declared in the said deed as partners :

(i) Smt.Gyan Devi.-Mother-share 30%

(ii) Bal Krishan Agrawal Son share 35 %

(iii) Chandra Mohan-Son-share 35%

3. The aforesaid partnership deed was registered with the Registrar of Firms on December 2, 1967, and an account of the firm was opened with the Bank of Baroda, M.I. Road, Jaipur, on November 23, 1967. All the three partners were authorised to opt-rate the said bank account. Smt. Gyan Devi, mother of the other two partners, had brought in as per the books of the firm, a capital of Rs. 22,631. She rema