B.S.Dhillon, J.

1. The assessees father, Shri Shamsher Singh was the managing director of the Amritsar Sugar Mills Ltd., Amritsar. He died on May 18, 1970. Before his death, ho used to be assessed as " individual" in respect of his income from salary, dividends and interest on deposits, etc.

2. By a will dated May 15, 1970, Shri Shamsher Singh bequeathed his entire property exclusively to the assessee, his only son. After the death of Shri Shamsher Singh, the ITO made two separate assessments in respect of his income for the assessment year 1971-72, one in respect of his income for the period from January 1, 1970 to May 18, 1970, in the hands of his son, Sampuran Singh, the assessee, as his legal heir under Section 159 of the I.T. Act, 1961 (hereinafter referred to as "the Act") and the other relating to the period from May 18, 1970 to December 31, 1970, also in the hands of Shri Sampuran Singh, as the executor of his estate under Section 168 of the Act. Since the assessee was also an income-tax assessee with the financial year as his accounting year, a separate assessment for the assessment year 1971-72, was made in his individual capacity in respect of his income from sal