RAMANUJAM J.

The assessee-firm, M/s. Kalpana Theatres, was originally constituted under a deed of partnership dated March 21, 1962. Its four partners were Sarvashri M. S. Hussain, K. C. Sampathkumar, K. C. Rajagopal and Abdul Shukkoor. The business of the firm was the exhibition of films in a cinema theatre constructed by the first three partners, the fourth partner being the working partner. The first assessment year for the firm was the assessment year 1963-64 and the accounts of the firm were closed on the 31st of March each year. There was a reconstitution of the firm by a deed dated April 1, 1969, under which the partnership consisted of only the first three partners, Abdul Shukkoor having left the firm on March 31, 1969. On December 24, 1969, the movable properties of the firm were sold to one K. S. Santhana Devi and one Sukumaran for Rs. 1, 25, 000. The immovable properties of the firm were agreed to be sold for a sum of Rs. 3, 50, 000 to one Krishnaswami Chettiar, Santha Devi, Sulochana and Sukumaran. The sale deed in relation to immovable properties was executed on July 29, 1974, by the three partners on production of a certificate under s. 230A of the I.T. Act,