In compliance, with the requisition of the High Court under section 66(2) of the Indian Income-tax Act in Tax Case Petition No. 21 of 1960, dated 4th August, 1960, we state the case, agreed to by the parties, and refer it to the High Court. This questions of law on which the Tribunal has been directed to state the case are as follows :

"(1) Whether, on the facts and in circumstances of the case, the Tribunal was justified in refusing to admit the additional grounds of appeal ?

(2) Whether the computation of the profits with reference to the sale of a portion of the properties was justified in law ?" *

We shall, therefore, confine ourselves as far as possible to the facts relevant to those questions.

2. The assessee's father, Kadiresan Chettiar, and one Arunachalam Chettiar were carrying on money-lending business in partnership at Ceylon and when the partnership was dissolved by the death of the assessee's father on 29th May, 1935, that partnership owned a number of properties; one of such, which came to the share of the assessee, was Girivalai Estate. The assessee was a minor aged 9 at the time of his father's death. The assessee attained majority in or about March, 1947,