VEERASWAMI J.

These matters have been heard together because of common points. The tax cases relate to the assessment years 1958-59 and 1959-60 and the writ petitions to the years 1961 to 1965. M.V.S. Kadirvelu Nadar of Tuticorin obtained in 1941 from the Government a lease of certain forest lands of a total extent of 410 acres, of which 310 are situate in Papanasam Hills and the rest in the Ambasamudram range. The entire lands have been used for raising cardamom plantations. The leases were for a fixed period of 25 years, but eligible to renewal. In about 1944, the lessee entered into a partnership with W.P.A.R. Chandrasekaran and his two brothers, Ramamurti and Rajagopalan, in respect of 310 acres. This partnership would appear to have been reduced in writing by a document dated May 10, 1954. For the year 1957-58, the lessee was assessed on the total income from the entire extent of 410 acres. For the following assessment year, the assessee claimed to have entered into a partition with effect from August 17, 1957, said to have been confirmed by a registered document dated August 1, 1958, by which the extent of 310 acres was partitioned as between himself and his four s