Rajagopalan, J.-Ebenezer, the father of the petitioner Alfred, was an income-tax assessee. Ebenezer had income from the money-lending and Abkari businesses that he carried on in addition to income from immovable properties. He adopted the official financial year ending with 31st March, as his year of account. The assessment of his income for the assessment year 1944-45 was completed during his lifetime.

Ebenezer died intestate on 22nd November, 1945. His heirs and legal representatives were his son and eight daughters, four of whom were minors. Six ©f the daughters filed O.S. No. 121 of 1948 on the file of the Sub-Court, Salem, for the administration of the estate of the deceased Ebenezer and for partition of the properties between his nine co-heirs. On 27th October, 1949, the Sub-Court appointed Mr. Lakshmanan, an Advocate, as the receiver of the properties of Ebenezer. The Receiver appears to have taken charge of most of the immovable properties and to have realised the income therefrom till he was discharged on 15th January, 1953. He filed his accounts into Court on 4th November, 1950, 4th June, 1951, 2nd February, 1952, and 4th November, 1952. On 26th September, 1950 there was

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