PATHAK, J. : This is a reference made by the Income-tax Appellate Tribunal under Section 66(1) of the Income-tax Act, 1922.

2. The assessee is a registered firm consisting of six partners, one of whom, Nanhi Devi, enjoys a share of four annas in the firm. On Bhado Sudi 13, Sambat 2010, the account of Nanhi Devi in the books of the assessee firm disclosed an opening credit balance of Rupees 1,57,056-14-6. On the same day, her account was debited with a sum of Rs. 1,01,000 and various sums totalling this amount were credited in the accounts of different persons in the books of the firm, among them being a sum of Rs. 15,000 credited in the account of the deity Sri Parmanand Behariji Maharaj. The sums were credited in these several accounts at the instance of Nanhi Devi as gifts made by her. Excepting the deity, the recipients of the remaining sums were the descendants of the brother of Nanhi Devi's husband, Nanhi Devi herself being a childless widow. The transfer entries in the cash book of the firm were signed by the donees personally and where they were minors were signed by their natural guardians. In the case of the deity, however, it seems that one Sri Ram Gupta appended