{"id":224686,"date":"1956-02-15T00:00:00","date_gmt":"1956-02-14T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/firm-of-bhagat-ram-mohanlal-vs-the-commissioner-of-excess-on-15-february-1956"},"modified":"2015-09-06T14:20:51","modified_gmt":"2015-09-06T08:50:51","slug":"firm-of-bhagat-ram-mohanlal-vs-the-commissioner-of-excess-on-15-february-1956","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/firm-of-bhagat-ram-mohanlal-vs-the-commissioner-of-excess-on-15-february-1956","title":{"rendered":"Firm Of Bhagat Ram Mohanlal vs The Commissioner Of Excess … on 15 February, 1956"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Firm Of Bhagat Ram Mohanlal vs The Commissioner Of Excess … on 15 February, 1956<\/div>\n
Equivalent citations: 1956 AIR 374, \t\t 1956 SCR 143<\/div>\n
Author: T V Aiyyar<\/div>\n
Bench: Aiyyar, T.L. Venkatarama<\/div>\n
           PETITIONER:\nFIRM OF BHAGAT RAM MOHANLAL\n\n\tVs.\n\nRESPONDENT:\nTHE  COMMISSIONER  OF EXCESS PROFITS  TAX,  MADHYA  PRADESH,\n\nDATE OF JUDGMENT:\n15\/02\/1956\n\nBENCH:\nAIYYAR, T.L. VENKATARAMA\nBENCH:\nAIYYAR, T.L. VENKATARAMA\nDAS, SUDHI RANJAN\nBHAGWATI, NATWARLAL H.\n\nCITATION:\n 1956 AIR  374\t\t  1956 SCR  143\n\n\nACT:\nIndian\tIncome-Tax Act, 1922 (XI of 1922),  s.\t26:-A-Excess\nProfits\t Tax Act, 1940 (Act XV of 1940), ss. 7,8(1) and\t 20-\nRegistration  of  appellant  firm-Partners-Hindu   undivided\nfamily\tconsisting  of karta and his two  brothers  and\t two\nothers-Made profits in two accounting years and assessed  to\nexcess\tprofits-Loss during the succeeding year-Profits\t set\noff  against loss under s. 7 of the Excess Profits Tax\tAct-\nPartition of joint family-Appellant firm reconstituted under\nfresh agreement-Consisting of five partners-Erstwhile  karta\nand  his  two brothers and two previous\t partners-Whether  a\nchange\tin  the\t persons carrying  on  business\t within\t the\nmeaning\t of  S. 8(1) of the Excess Profits  Tax\t Act-Whether\nprevious  order\t paying back excess profits  to\t assessee  a\nmistake\t apparent on the record within the meaning of s.  20\nof the Excess Profits Tax Act.\n\n\n\nHEADNOTE:\n   The firm of Bhagat Ram Mohan Lal-Appellant-constituted on\n23-8-1940 was registered under s. 26-A of the Indian Income-\ntax  Act,  the\tpartners  of  the  firm\t according  to\t the\nregistration  certificate  being (1) Bhagat  Ram  Mohan\t Lal\n(Hindu\tundivided  family), (2) Richpal\t and  (3)  Gajadhar,\ntheir  shares  being  respectively 8 annas, 4  annas  and  4\nannas.\t Mohan\tLal was the karta of the  aforesaid  family,\nwhich  consisted of himself and his two brothers,  Chhotelal\nand  Bansilal.\tThe firm made profits during the  accounting\nyears  ending  1943  and 1944 on which it  was\tassessed  to\nexcess\tprofits tax respectively of Rs. 10,023\/5\/-  and\t Rs.\n13,005\/5\/-.  During the year 19441945 it sustained a loss of\nRs.  15,771  and  adding thereto  Rs.  37,800  the  standard\nprofits\t for  the business, the Excess Profits\tTax  Officer\ndetermined  the\t deficiency of profits for the year  at\t Rs.\n53,571 . Acting under s. 7 of the Excess Profits Tax Act the\nExcess\tProfits\t Tax Officer passed an order  on  23-12-1946\nwhereby\t after setting off the profits of the firm  for\t the\nyears ending 1943 and 1944 against the deficiency of profits\nduring\tthe  year ending 1945, he directed a refund  of\t Rs.\n23,028\/10\/-  which had been paid by the appellant as  excess\nprofits tax for those years.\n  At the commencement of the assessment year 1944-1945 there\nwas  a partition in the joint family of which Mohan Lal\t was\nerstwhile karta, he and his two brothers becoming divided in\nstatus.\t  As  a\t result\t thereof  the  appellant  firm\t was\nreconstituted  under  an  agreement  dated  17-10-1944,\t the\npartners  of  the firm being five in number.   There  was  a\nreconstitution of the firm with respect to persons\n144\nand  their  shares.   According to s.  8(1)  of\t the  Excess\nProfits Tax Act the change in the persons is deemed to bring\nabout  a  discontinuation  of  the  old\t business  and\t the\ncommencement  of  a new one and if that section\t applied  no\nrelief\tcould have been granted to the appellant under s.  7\nof the Act.\nThe  facts as to the reconstitution of the firm having\tcome\nto  the knowledge of the Commissioner of Excess Profits\t Tax\nhe issued a notice under s. 20 of the Excess Profits Tax Act\ncalling\t upon the appellant why the order of Excess  Profits\nTax Officer dated 23-12-1946 should not be set aside on\t the\nground\t of   mistake  as  he  had  failed  to\t take\tinto\nconsideration  the  change in the constitution of  the\tfirm\nwhich took place on 17-10-1944.\t After hearing the appellant\nthe  Commissioner held by his order dated 15-3-1950 that  on\nthe  facts disclosed there was a change in the\tpersons\t and\nthat the award of relief under s. 7 of the Act by the Excess\nProfits Tax Officer was a mistake.  He set aside order\tonly\nso far as Bhagat Ram Mohan Lal was concerned maintaining  it\nwith regard to two others.\nOn an application for a writ of certiorari and for a writ of\nprohibition  under  Art. 226 of the  Constitution  the\tHigh\nCourt upheld the order of the Commissioner.  On an appeal by\nSpecial Leave to the Supreme Court:\nHeld (1) that by reason of the partition of the joint family\nand the reconstitution of the firm under the deed dated\t 17-\n10-1944\t there\twas  a change in  the  persons\tcarrying  on\nbusiness within s. 8(1) of the Act.\nIf  all the five persons who were mentioned as\tpartners  in\nthe deed of 1944 were partners of the old firm, there  would\nbe no change in the persons carrying on the business  within\ns.  8(1) of the Act by the mere fact of reshuffling  of\t the\nshares\tamong them but the real question  for  determination\nwas whether Chhotelal and Bansilal were partners in the firm\nconstituted  on\t 23-8-1940.   It  is  not  in  dispute\tthat\nMohanlal  was  the karta of the joint family,  and  that  he\nentered into the partnership on 23-8-1940 as such karta.  It\nis well settled that when the karta of a joint Hindu  family\nenters into a partnership with strangers, the members of the\nfamily do not ipso facto become partners in that firm.\tThey\nhave  no right to take part in its management or to sue\t for\nits  dissolution.  The creditors of the firm would no  doubt\nbe  entitled  to  proceed against the  joint  family  assets\nincluding  the\tshares of the  non-partner  copareeners\t for\nrealisation  of their debts.  But that is because under\t the\nHindu Law, the karta has the right when properly carrying on\nbusiness  to  pledge the credit of the joint family  to\t the\nextent\tof  its assets, and not because the  junior  members\nbecome\tpartners  in  the business.  The  liability  of\t the\njunior\t members  arises  by  reason  of  their\t status\t  as\ncoparceners and not by reason of any contract of partnership\nand  it would follow therefore that when Mohanlal  became  a\npartner\t of  the firm on 23-8-1940  Chhotelal  and  Bansilal\ncould  not  be\theld by reason of that fact  alone  to\thave\nbecome partners therein,\n145\nAccordingly whether the question was to be considered on the\nprinciples  of Hindu law or on the principles of the  Excess\nProfits\t Tax Act there was a change in the personnel of\t the\nfirm on 17-10-1944 and the matter fell within s. 8(1) of the\nAct.\n(2)  That  there  was a mistake apparent on  the  record  as\nrequired  by  s.  20 of the Act\t and  the  Commissioner\t had\njurisdiction to pass the order dated 15-3-1950 which he did.\nThere  was  no force in the contention that  the  record  in\nExcess Profits Tax proceedings consisted in the present case\nof  the\t only order dated 23-12-1946 and that the  facts  on\nwhich  the proceedings were taken under s. 20,\tnamely,\t the\nconstitution  of  the  firm on\t23-8-1940  and\tthe  changes\neffected therein on 17-10-1944 were not recited therein\t and\nthat  in  consequence there were no materials  on  which  an\norder  could  have been passed under  that  section  because\nthough the order of the Excess Profits Tax Officer dated 23-\n12-1946 does not mention these facts these facts appear from\nthe record of the income-tax proceedings which included the,\nregistration  certificate of the firm under s. 26-A  of\t the\nIncome-Tax  Act and the returns made by the firm  disclosing\nthe names of the partners and their respective shares.\tFur-\nther  the fact is that the proceedings under the  two  Acts,\nnamely,\t the Excess Profits Tax Act and the Income Tax\tAct,\nare interdependent.\nLachman Das v. Commissioner of Income-Tax ([1948] 16 I. T.R.\n35),  Sundar  Singh Majithia v. Commissioner  of  Income-tax\n([1942]\t 10  I.T.R.  457), Shanmugavel\tNadar  and  Sons  v.\nCommissioner  of  Income-tax  ([1948]  16  I.T.R.  355)\t and\nShapurji  Pellonji v. Commissioner of Income-tax ([1945]  13\nI.T.R. 113), referred to.\n\n\n\nJUDGMENT:\n<\/pre>\n
CIVIL APPELLATE JURISDICTION: Civil Appeal
\nNo. 139 of 1953.\n<\/p>\n
Appeal\tby special leave from the judgment and\torder  dated
\nthe  22nd  day of August 1950 of the Nagpur  High  Court  in
\nMiscellaneous Petition No. 67 of 1950.\n<\/p>\n
Radhey Lal Agarwala and B. P. Maheshwari, for the appellant.
\nC.   K.\t Daphtary, Solicitor-General of India (G.  N.  Joshi
\nand R. H. Dhebar, with him) for the respondents.
\n1956.  February 15.  The Judgment of the-Court was delivered
\nby.\n<\/p>\n
VENKATARAMA AYYAR J.-The firm of Bhagat Ram Mohanlal,  which
\nis  the appellant before us, was constituted  on  23-8-1940,
\nand  registered under section 26-A of the Indian  Income-tax
\nAct, The partners of
\n146<\/span>
\nthe firm, according to the registration certificate, were
\n(1)  Bhagat Ram Mohanlal, Hindu undivided family,
\n(2)  Richpal and (3) Gajadhar, their shares being
\nrespectively  8 annas, 4 annas and 4 annas   Mohan  lal\t was
\nthe, karta of the aforesaid joint family, which consisted of
\nhimself and his two brothers, Chhotelal and Bansilal, and he
\nentered\t into  the  partnership as  such  karta.   The\tfirm
\ncarried\t on business at Drug in Madhya Pradesh as the  agent
\nof the Government for the purchase of foodgrains, and during
\nthe  accounting years ending 1943 and 1944, it made  profits
\non which it was assessed to excess profits tax\trespectively
\nof Rs. 10,023-5-0 and Rs. 13,005-5-0.  During the year 1944-
\n1945 it sustained a loss of Rs. 15,771, and adding it to the
\nsum  of\t Rs. 37,800 which was the standard profits  for\t the
\nbusiness,  the\tExcess Profits Tax  Officer  determined\t the
\ndeficiency of profits for the year at Rs. 53,571.  Section 7
\nof  the Excess Profits Tax Act, hereinafter referred  to  as
\nthe Act, provides that when there is a deficiency of profits
\nin  any\t chargeable accounting period in any  business,\t the
\nprofits of that business during the previous years shall  be
\ndeemed\tto  be\treduced\t eo extanti,  and  that\t the  relief
\nnecessary to give effect to the reduction shall be given  by
\nrepayment  of the tax paid or otherwise.  Acting under\tthis
\nsection,  the Excess Profits Tax Officer passed an order  on
\n23-12-1946 whereby after setting off the profits of the firm
\nfor the years ending 1943 and 1944 against the deficiency of
\nprofits during the year ending 1945, he directed a refund of
\nRs.  23,028-10-0  which had been paid by  the  appellant  as
\nexcess profits tax for those years.\n<\/p>\n
  It  should  be mentioned that at the commencement  of\t the
\nassessment year 1944-1945 there was a partition in the joint
\nfamily\tof  which  Mohanlal was the erstwhile  karta,  as  a
\nresult of which he and his brothers, Chhotelal and Bansilal,
\nbecame divided in status.  Consequent on this disruption  of
\nthe joint family, the appellant firm was reconstituted under
\nan  agreement dated 17-10-1944.\t Under this  agreement,\t the
\npartners of the firm were five in number, Richpal  .Gajadhar
\nMohanlal, Chhotelal and Bansilal, the two
\n147<\/span>
\nformer\tbeing entitled to 5 annas share each and the  latter
\nthree  to 2 annas each.\t There was thus a reconstitution  of
\nthe  firm  both with reference to the persons who  were\t its
\npartners  and the shares which were allotted to them.\tNow,
\nsection\t 8(1) provides, omitting what is not material,\tthat
\n“as from the date of any change in the persons carrying on a
\nbusiness,  the\tbusiness  shall\t be  deemed  to\t have\tbeen
\ndiscontinued and a new business commenced”.  If this section
\napplied,  then\tno  relief could have been  granted  to\t the
\nappellant under section 7 of the Act.\n<\/p>\n
  The  facts  relating\tto the reconstitution  of  the\tfirm
\nhaving\tcome to the knowledge of the Commissioner of  Excess
\nProfits Tax on examination of the record, he issued a notice
\non  19-2-1948 calling upon the appellant to show  cause\t why
\nthe  order of -the Excess Profits Tax Officer  dated  23-12-
\n1946 should not be set aside on the ground of mistake.\tThis
\nnotice was issued under section 20 of the Act, which confers
\non  the\t Commissioner  authority  to  rectify  “any  mistake
\napparent  from the record”.  The mistake, according  to\t the
\nCommissioner,  consisted in the Excess Profits\tTax  Officer
\nfailing\t “to  take  into consideration\tthe  change  in\t the
\nconstitution  of  the firm which took place  on\t 17-10-1944,
\nconsequent  on the disruption of the joint Hindu  family  of
\none of the partners”.  The appellant appeared in response to
\nthe notice, and contended that on the facts the\t proceedings
\nunder section 20 were misconceived.  The facts on which\t the
\nproceedings were taken were not themselves disputed.  By his
\norder  dated  15-3-1950 the Commissioner held  that  on\t the
\nfacts  disclosed  on the record, there was a change  in\t the
\npersons\t carrying  on the business, and that  the  award  of
\nrelief under section 7 by the Excess Profits Tax Officer was
\na  mistake.  He, however, maintained the order dated  23-12-
\n1946  with  reference to Richpal and Gajadhar,\tand  set  it
\naside only so far as “Bhagat Ram Mohanlal, Hindu.  undivided
\nfamily”\t which was registered as partner on  23-8-1940,\t was
\nconcerned.   He further directed that Rs.  11,514-5-0  which
\nhad been refunded to it should be collected.\n<\/p>\n
148<\/span><\/p>\n
The appellant thereupon moved the High Court of Nagpur under
\narticle\t 226 for a writ of certiorari quashing the order  of
\nthe   Commissioner  dated  15-3-1950  and  for\ta  writ\t  of
\nprohibition restraining the authorities from collecting\t Rs.
\n11,514-5-0  under that order.  By their judgment dated\t22nd
\nAugust 1950, the learned Judges agreed with the Commissioner
\nthat  by reason of the partition there was a change in\tthe-
\npersons\t who  carried on the business, and  that  the  order
\ndated  23-12-1946 was contrary to section 8(1) of  the\tAct.
\nThey  also held that as the mistake appeared on the face  of
\nthe record, the Commissioner had jurisdiction under  section
\n20  of\tthe  Act to pass the order which  he  did.   In\t the
\nresult, the writs -were refused.  Against this judgment, the
\nappellant prefers this appeal by special leave.
\n  Two  questions have been raised for our  determination  in
\nthis  appeal: (1) whether by reason of the partition of\t the
\njoint  family and the reconstitution of the firm  under\t the
\ndeed  dated  17-10-1944 there was a change  in\tthe  persons
\ncarrying on business within section 8(1) of the Act; and (2)
\nwhether the order of the Commissioner dated 15-3-1950 is bad
\non  the ground that there was no mistake apparent  from\t the
\nrecord, as required by section 20 of the Act.  On the  first
\nquestion,  the\tcontention  of the appellant  is  that\twhen
\nMohanlal entered into partnership with Richpal and  Gajadhar
\non 23-8-1940 as karta of the joint family, the other members
\nof  that  family,  Chhotelal and Bansilal,  also  became  in
\nsubstance  partners  of the firm, and that  when  they\twere
\nmentioned  eo nominee as partners in the deed  dated  17-10-
\n1944  the change was more formal than substantial, and\tthat
\nfurther\t the  fact that there was a re-allotment  of  shares
\namong  the  partners  would not amount to a  change  in\t the
\npersons\t who carried on the business.  We agree that if\t all
\nthe five persons who were mentioned as partners in the\tdeed
\nof  1944  were partners of the old firm, there would  be  no
\nchange\tin  the\t persons carrying  on  the  business  within
\nsection\t 8(1) of the Act by the mere fact of reshuffling  of
\nshares\tamong  them.  But the real question that has  to  be
\ndecided
\n149<\/span>
\nis whether Chhotelal and Bansilal were partners in the firm,
\nwhich was constituted on 23-8-1940.  The appellant  contends
\nthat  they  were, both according to the Hindu law  and\teven
\napart\tfrom   it,  under  the\tgeneral\t law   relating\t  to
\npartnerships.\n<\/p>\n
  It  is not in dispute that Mohanlal was the karta  of\t the
\njoint  family, and that he entered into the  partnership  on
\n23-8-1940  as such karta.  It is well settled that when\t the
\nkarta of a joint Hindu family enters into a partnership with
\nstrangers,  the\t members  of the family do  not\t ipso  facto
\nbecome\tpartners in that firm.\tThey have no right  to\ttake
\npart  in its management or to sue for its dissolution.\t The
\ncreditors of the firm would no doubt be entitled to  proceed
\nagainst the joint family assets including the shares of\t the
\nnonpartner co-parceners for realisation of their debts.\t But
\nthat is because under the Hindu law, the karta has the right
\nwhen  properly carrying on business to pledge the credit  of
\nthe  joint  family  to the extent of  its  assets,  and\t not
\nbecause the junior members become partners in the  business.
\nIn  short, the liability of the latter arises by  reason  of
\ntheir status as copartners and not by reason of any contract
\nof partnership by them.\t It would therefore follow that when
\nMohanlal  became  a  partner  of  the  firm  on\t  23-8-1940,
\nChhotelal  and Bansilal could not be held by reason of\tthat
\nfact alone, to have become partners therein.
\n  It is argued that when that firm was constituted on  23-8-
\n1940   the  persons  who  entered  into\t the   contract\t  of
\npartnership  were not merely Mohanlal as karta of the  joint
\nfamily\tbut also Chhotelal and Bansilal in their  individual
\ncapacity, and that therefore they became partners under\t the
\nordinary partnership law.  But the registration\t certificate
\nof  the\t firm  while showing  “Bhagat  Ram  Mohanlal,  Hindu
\nundivided  family” as a partner, makes no mention of  either
\nChotelal or Bansilal as partners.  The contention that\tthey
\nalso  became in their individual capacity  partners  appears
\ntherefore  to  be  an afterthought, and is  opposed  to\t the
\nfindings  of the learned Judges of the High Court.  This  is
\nsufficient,  without  more, to dispose of  this\t contention.
\nBut even apart from this,
\n20<\/span>
\n150<\/span>
\nit  is\tdifficult to visualise the situation which  the\t ap-
\npellant contends for, of a Hindu joint family entering\tinto
\na  partnership\twith  strangers through its  karta  and\t the
\njunior members of the family also becoming at the same\ttime
\nits partners in their personal capacity.  In Lachhman Das v.
\nCOmmissioner  of Incometax(1), it was held by  the  Judicial
\nCommittee that the karta of a joint Hindu family could enter
\ninto   partnership   with  an  individual  member   of\t the
\ncoparcenary  quoad his separate property.  It was also\theld
\nby  the Privy Council in Sundar Singh Majithia\tv.  Commiss-
\nioner of Income-tax(2) that there was nothing in the Income-
\ntax Act to prohibit the members of a joint Hindu family from
\ndividing  some\tproperties, while electing to  retain  their
\njoint  status,\tand  carrying on  business  as\tpartners  in
\nrespect\t of those properties. treating them as its  capital.
\nBut  in\t the  present case, the\t basis\tof  the\t partnership
\nagreement  of  1940 is that the family was  joint  and\tthat
\nMohanlal  was  its  karta  and\tthat  he  entered  into\t the
\npartnership  as karta on behalf of the joint family.  It  is
\ndifficult to reconcile this position with that of  Chhotelal
\nand  Bansilal  being  also partners in\tthe  firm  in  their
\nindividual  capacity, which can only be in respect of  their
\nseparate  or divided property.\tIf members of a\t coparcenary
\nare to be regarded as having become partners in a firm\twith
\nstrangers, they would also become under the partnership\t law
\npartners inter se, and it would cut at the very root of\t the
\nnotion\tof  a  joint  undivided family\tto  hold  that\twith
\nreference  to coparcenary properties the members can at\t the
\nsame time be both coparceners and partners.
\n To get over this difficulty, it was suggested that all\t the
\nthree  coparceners might be regarded as having entered\tinto
\nthe  contract of partnership as kartas of the joint  family.
\nBut  even  if  that  could be  done  consistently  with\t the
\nprinciples of Hindu law, the very pleadings of the appellant
\nare against such a supposition being made, affirming as they
\ndo  that  it was only Mohanlal that was the karta,  not\t the
\nothers.\n<\/p>\n
(1) [1948]16 I.T.R 35.\n<\/p>\n
(2) [1942] 10 I.T.R. 457.\n<\/p>\n
151<\/span><\/p>\n
The  contention,  therefore,  that  Chhotelal  and  Bansilal
\nshould be held to have become partners in the old firm under
\nthe agreement dated 23-8-1940 cannot be maintained.
\n  The  question\t whether there was a change in\tthe  persons
\ncarrying on the business may now be considered independently
\nof  the\t principles  of\t Hindu Law or  the  general  law  of
\nPartnership and with special reference to the provisions  of
\nthe Indian Excess Profits Tax Act.  Section 2(17) of the Act
\ndefines\t a ‘person’ as including a joint  family.   Applying
\nthis  definition., who were the members of the firm when  it
\nwas constituted on 23-8-1940?  Richpal, Gajadhar and “Bhagat
\nRam  Mohanlal, Hindu undivided family” consisting  of  three
\ncoparceners,  Mohanlal,\t Chhotelal and\tBansilal,  it  being
\nimmaterial for the present purpose whether the karta of\t the
\nfamily\twas only Mohanlal, or all the three of them.   Then,
\nthe family became divided in 1944, and the result of it\t was
\nthat  one of the three persons who were partners in the\t old
\nfirm, “Bhagat Ram Mohanlal” ceased to exist.  On 17-10-1944,
\nthe  two  surviving partners of the old\t firm,\tRichpal\t and
\nGajadhar,  entered  into  a  contract  of  partnership\twith
\nMohanlal,  Chhotelal  and  Bansilal.   The  erstwhile  joint
\nfamily of which they were members not being a partner in the
\nnew  firm,  it\thaving\tceased to exist\t by  reason  of\t the
\npartition,  there  was, having regard to the  definition  in
\nsection\t 2(17)\tof  the Act, a change  in  the\tpersons\t who
\ncarried\t on  the  business.   That was\tthe  view  taken  in
\nShanmugavel  Nadar  and\t Sons V.   Commissioner\t of  Income-
\ntax(1),\t and  we  agree with it.  Whether  the\tquestion  is
\nconsidered  on\tthe  principles\t of  Hindu  law\t or  on\t the
\nprovisions of the Excess Profits Tax Act, there was a change
\nin  the personnel of the firm on 17-10-1944, and the  matter
\nfalls within section 8(1) of the Act.\n<\/p>\n
(2) The next question for determination is whether the order
\nof  the Commissioner dated 153-1950 is not justified by\t the
\nprovisions  of\tsection 20 of the Act for  the\treason\tthat
\nthere was no mistake apparent from the record.\tThe argument
\nin support of this conten-\n<\/p>\n
(1)  [1948]16 I.T.R. 355,
\n152<\/span>
\ntion  is  that\tthe record in the Excess  Profits  Tax\tpro-
\nceedings  consisted  in the present case of only  the  order
\ndated  23-12-1946, that the facts on which  the\t proceedings
\nwere taken under section 20, namely, the constitution of the
\nfirm on 23-8-1940 and the changes effected therein on 17-10-
\n1944  were  not recited therein, and that,  in\tconsequence,
\nthere  were no materials on which an order could  have\tbeen
\npassed under that section.  It is true that the order of the
\nExcess Profits Tax Officer dated 23-12-1946 does not mention
\nthese facts, but they appear from the record of the  income-
\ntax proceedings which included the registration certificates
\nof the firm under section 26-A of the Income-tax Act and the
\nreturns\t made  by  the\tfirm disclosing\t the  names  of\t the
\npartners and their respective shares.  It is argued for\t the
\nappellant  that\t these\trecords were  inadmissible  for\t the
\npurpose of proceedings under section 20 of the Act,  because
\nthe record referred to and contemplated by that section must
\nbe  the\t record of the excess profits tax  proceedings,\t and
\nthat the records of the income-tax proceedings could not  be
\nused  under that section.  We are unable to agree with\tthis
\ncontention.  Section 22(1) of the Act provides that:
\n  “Notwithstanding anything contained in the Indian  Income-
\ntax Act, 1922, all information contained in any statement or
\nreturn made or furnished under the provisions of that Act or
\nobtained  or collected for the purposes of that Act  may  be
\nused for the purposes of this Act”.\n<\/p>\n
  Section  22(2)  similarly makes the record of\t the  excess
\nprofits tax proceedings admissible in proceedings under\t the
\nIndian\tIncome-tax  Act.  The fact is that  the\t proceedings
\nunder  the two Acts are interdependent.\t  Assessments  under
\nthe  Excess  Profits  Tax Act are, subject  to\tthe  special
\nprovisions of that Act, made on the basis of the assessments
\nmade under the provisions of the Indian Income-tax Act.\t The
\nsame  officers are in chargev of the proceedings under\tboth
\nthe enactments.\t The order of the Excess Profits Tax Officer
\ndated  23-12-1946 refers in terms to the order\tdated  28-9-
\n1946 passed in the proceedings for assess-\n<\/p>\n
153<\/span><\/p>\n
ment  of income-tax on the appellant, and the deficiency  of
\nprofits is worked out on the basis of the loss of Rs. 15,771
\nas  ascertained\t therein.   We\tsee  no\t substance  in\tthis
\ncontention, which must accordingly be rejected.
\n  It  was finally contended that the particulars recited  in
\nthe registration certificate as to who were all partners  of
\nthe firm were not conclusive, and that the appellant was not
\nestopped  from\tproving\t that even  on\t23-8-1940  the\treal
\npartners  were\tall the five persons mentioned in  the\tdeed
\ndated  17-10-1944, and the decision in Shapurji Pellonji  v.
\nCommissioner  of Income-tax(1) was relied on in\t support  of
\nthe  position.\t It  is undoubted law  that  the  income-tax
\nauthorities  are  not estopped by the fact  of\tregistration
\nfrom going behind the certificate, and deciding who the real
\npartners  of  the  firm are.  But  can\tthe  assessee  whose
\nstatement is the basis on which the registration is made and
\nwho   has   possibly  been  benefited\tthereby\t  deny\t its
\ncorrectness,  when the facts mentioned therein turn  out  to
\nhis disadvantage?  It is unnecessary to consider this point,
\nin view of our decision that on the facts as pleaded by\t the
\nappellant,  Chhotelal and Bansilal could not be regarded  as
\npartners  in the old firm.  We may add that this  contention
\ndoes  not  appear  to  have  been  put\tforward\t before\t the
\nCommissioner  when notice was issued to the appellant  under
\nsection\t 20  of the Act.  If any such  contention  had\tbeen
\nraised, it would have been open to the Commissioner to\thave
\ntaken action under section 19 of the Act.\n<\/p>\n
In  the\t result,  the appeal fails, and\t is  dismissed\twith
\ncosts.\n<\/p>\n
(1) [1945] 13 I.T.R. 118.\n<\/p>\n
154<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Firm Of Bhagat Ram Mohanlal vs The Commissioner Of Excess … on 15 February, 1956 Equivalent citations: 1956 AIR 374, 1956 SCR 143 Author: T V Aiyyar Bench: Aiyyar, T.L. Venkatarama PETITIONER: FIRM OF BHAGAT RAM MOHANLAL Vs. RESPONDENT: THE COMMISSIONER OF EXCESS PROFITS TAX, MADHYA PRADESH, DATE OF JUDGMENT: 15\/02\/1956 […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-224686","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nFirm Of Bhagat Ram Mohanlal vs The Commissioner Of Excess ... on 15 February, 1956 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/firm-of-bhagat-ram-mohanlal-vs-the-commissioner-of-excess-on-15-february-1956\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Firm Of Bhagat Ram Mohanlal vs The Commissioner Of Excess ... on 15 February, 1956 - 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