JUDGMENT

Pathak, J. - The petitioner is aggrieved by proceedings for recovery of Income Tax taken against him-pursuant to assessment orders dated June 26, 1964, for the assessment years 1951-52 to 1956-57, made against the United Motor Transport Service Association.

2. The petitioner alleges that there were two motor vehicles, one owned by him and the other by his wife, which were operated for the carriage of passengers along with the motor vehicles owned by other operators under the common management of the United Motor Transport Service Association; that the income from the operation of the two vehicles owned by him and his wife was assessed in the hands of his Hindu undivided family for the assessment years 1951-52 to 1956-57 on the basis that it was the income of the family and, it is said, the tax due thereon was paid by the family. Subsequently, the income was also assessed in the hands of the United Motor Transport Service Association for the same assessment years and the tax assessed is now sought to be recovered from the petitioner. Pursuant to the recovery proceedings, it is alleged that it is proposed to arrest the petitioner. The house property of the petitioner and the m