MRS. A. SUBBULAKSHMY, J.

The assessee is an HUF. The Karta of this joint family is Shri A. L. Ramanathan son of Shri L. Alagusundaram Chettiyar. On 12th April, 1952, there was a partition between Shri Alagusundaram Chettiyar and his brother Shri L. Narayanan Chettier. On 12th September, 1955, there was a partition in the joint family of which L. Alagusundaram Chettiyar was the Karta and his three sons viz. A. L. Lakshmanan, AL. Periannan and A. L. Ramanathan were the other co-parceners. Dispute arose in the family and an interim agreement was entered into on 19th August, 1980, under which the assessee's side was to receive Rs. 8 lakhs and certain lands in Kothagai Village and in return they were required to transfer half of their share holdings in Mahalakshmi Textile Mills Ltd. Lakshmi Lines Ltd., and Charlie Engineering Co. Ltd. to the other side subject to full settlement later. On 20th August, 1981, the final agreement was drawn up according the oral agreement dt. 6th May, 1981 under which the assessee's side was to receive a further amount of Rs. 11 lakhs which was paid on 19th June, 1981, in addition to Rs. 8 lakhs paid on 9th September, 1980 and also to keep the la