RAMACHANDRA IYER, J.

This reference under section 66(2) of the Indian Income-tax Act relates to the assessment years, 1939-40 and 1941-42 to 1946-47, the relative year of account ending on the 12th of April of each year of assessment. One Arunachalam Chettiar (senior) and his son, Arunachalam (junior), constituted members of a Hindu undivided family. They were residents in India. The family had considerable properties in India and outside, comprising tea and rubber estates, coconut gardens and several money-lending businesses. Arunachalam Chettiar (junior) died in 1934, leaving behind him his widow, Umayal Achi. Arunachalam Chettiar (senior), who survived his son, died on February 22, 1938. On his death, the claimants to the properties were his two widows, Lakshmi Achi and Nachiar Achi, and widowed daughter-in-law, Umayal Achi. Some time prior to his death, that is, on February 8, 1938, Arunachalam Chettiar (senior) executed a will, making certain dispositions. Under the will, the executors were directed to arrange for the adoption of a son to each of the three ladies (such multiple adoption being presumably sanctioned by the custom of the Nattukottai Chettiar community). The will directed that, after the payment of legacies, the three adopted sons were to divide the properties equally. Umayal Achi, however, did not accept the will. She filed a suit in the Sub-Court, Devakottai, claiming a half share in the estate, left by her deceased father-in-law. The claim was laid on the basis of the rights conferred by the Hindu Women's Right to Property Act, 1937, under which the widow of the pre-deceased son of an individual who died after the coming into force of the Act was entitled to certain rights. Pending the suit, that is, on August 18, 1938, two advocates, Ramaswami Iyengar and Subramania Iyer, were appointed joint receivers to manage the properties involved in the suit. As a part of their management, the receivers continued the various businesses, which Arunachala (senior) had carried on in his lifetime The suit was resisted by the two widows of Arunachala (senior), who denied the right of Umayal Achi to inheritance. The trial court found that the will executed by the deceased was a genuine one, but that Umayal Achi would be entitled to one half share in all the properties in India and in the moveable properties situate outside India, subject to the payment of the legacies mentioned in the will. As regards the immovable properties situate outside India, the court held that succession to the properties would be governed by the law of the place where the properties were situate. In accordance with the judgment, a preliminary decree was passed on October 26, 1940. There were appeals against the decrees to this court; this court modified the decree of the lower court, restricting it to the non-agricultural and moveable properties situate in India. The judgment of the High Court is reported in Umayal Achi v. Lakshmi Achi. Umayal Achi filed an appeal against the decree of the High Court to the Federal Court. The Federal Court, by its judgment dated January 8, 1945, held that Umayal Achi would be entitled to one-half share in the separate non-agricultural properties left by the deceased and in the moveables. The court directed that there should be an ascertainment by the Subordinate Judge as to what were the separate properties that belonged to the deceased, in which the lady would have a right to a share. (The judgment of the Federal Court is reported in Umayal Achi v. Lakshmi Achi). In June, 1945, each of the three ladies adopted a son, as directed by the will. It is stated that there was an ante adoption agreement in each case, defining the rights inter se between the son to be adopted and the respective adoptive mother. Aggrieved by the judgment of the Federal Court, Umayal Achi filed an appeal to the Privy Council, after obtaining leave for the sameWhile the appeal was pending in the Privy Council, the ladies, on beha