Messrs Bapalal and Co. (Manufacturing) is the petitioner herein. The petitioner firm has been registered as a partnership firm under the Indian Partnership Act in 1933, the registration number being No. 63 of 1933. In the same year another partnership firm was also registered under the name and style of M/s. Bapalal and Co. (Diamonds) with registration number 64 of 1933. The respective registration certificates were issued by the Registrar of firms as M/s. Bapalal and Co. (Manufacturing Department) and M/s. Bapalal and Co. (Diamonds Department). According to the petitioner excepting for the fact that certain partners are common, the partnership firms are two independent and distinct entities. Though both the firms are situate in the same premises, they function separately. M/s. Bapalal and Co. (Diamonds) supply raw materials such as diamonds and gold to the petitioner and the latter manufactures the jewellery by setting the diamonds in gold. It returns the diamonds and gold received from M/s. Bapalal and Co. (Diamonds) in the form of diamond jewellery such as necklaces, ear studs and nose screw. The petitioner in return receives labour charges from M/s. Bapalal and Co.