Bhopinder Singh Dhillon, J.

1. Briefly stated the facts giving rise to this reference are that this assessee-firm known as Messrs. Jagan Nath Pyare Lal of Ludhiana had ten partners who were members of the two families and came into existence under the instrument of partnership executed on March 27, 1952. Padam Kumar was a minor in the said partnership. When he attained majority on October 1, 1956, he opted to continue as a full-fledged partner and a fresh instrument of partnership, copy of which is annexure "A" with the statement of the case, was executed, on Octobers, 1956, by 11 partners including Shri Rabinder Kumar, having Re. 1/2 share. On April 1, 1959, the partners decided to effect a change in the profits and losses-sharing ratio. A fresh deed, copy of which is annexure "B" with the statement of the case, was executed to that effect on April 1, 1959, and, consequently, an application dated September 2, 1959, for registration of the said firm under Section 26A of the Indian Income-tax Act, 1922, was filed on September 30, 1959, before the Income-tax Officer, A-Ward, Ludhiana, copy of which is annexure "C" with the statement of the case. Shri Rabinder Kumar, a partner