SRINIVASAN J.

Abdul Rahaman Rowther was the proprietary owner of a tobacco business. He entered into a partnership with his two married daughters and on that basis sought registration of the firm under section 26A of the Income-tax Act. The Income-tax Officer rejected the application holding that the "partnership deed was a sham document", that there was no genuine firm and that the business continued to be that of Abdul Rahaman Rowther alone. On appeal, the Appellate Assistant Commissioner concurred in these findings. He also thought that the interest of the two daughters in the firm was created by alleged gifts of Rs. 25, 000 to each of them by the father, and that the gifts were not valid as there was no handing over of the cash to the daughters. He was also inclined to hold that the making of a gift of a large part of the assets to only two of his daughters in preference to his several other children was unnatural. He further relied on the fact that on an earlier occasion Abdul Rahaman Rowther had also purported to form a partnership, the registration of which had also been rejected. There was a further appeal to the Tribunal, before whom it was contended that the gi