{"id":245005,"date":"1954-10-25T00:00:00","date_gmt":"1954-10-24T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/dhirajlal-girdharilal-vs-c-i-t-bombay-on-25-october-1954"},"modified":"2017-04-12T16:08:17","modified_gmt":"2017-04-12T10:38:17","slug":"dhirajlal-girdharilal-vs-c-i-t-bombay-on-25-october-1954","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/dhirajlal-girdharilal-vs-c-i-t-bombay-on-25-october-1954","title":{"rendered":"Dhirajlal Girdharilal vs C.I.T. Bombay on 25 October, 1954"},"content":{"rendered":"<div class=\"docsource_main\">Supreme Court of India<\/div>\n<div class=\"doc_title\">Dhirajlal Girdharilal vs C.I.T. Bombay on 25 October, 1954<\/div>\n<div class=\"doc_author\">Author: M C Mahajan<\/div>\n<div class=\"doc_bench\">Bench: M.C. Mahajan (Cj), S.R. Das, G. Hasan, N. H. Bhagwati, T.L.V. Aiyyar<\/div>\n<pre>           CASE NO.:\nAppeal (civil)  246 of 1953\n\nPETITIONER:\nDHIRAJLAL GIRDHARILAL   \n\nRESPONDENT:\nC.I.T. BOMBAY   \n\nDATE OF JUDGMENT: 25\/10\/1954\n\nBENCH:\nM.C. MAHAJAN (CJ) &amp; S.R. DAS &amp; G. HASAN &amp; N. H. BHAGWATI &amp; T.L.V. AIYYAR\n\nJUDGMENT:\n<\/pre>\n<p>JUDGMENT<\/p>\n<p>AIR 1955 SC 271<\/p>\n<p>The Judgment was delivered by MEHR CHAND MAHAJAN, C.J.\n<\/p>\n<p>MEHR CHAND MAHAJAN, C.J.\n<\/p>\n<p>This appeal by special leave is directed against an order of the High Court<br \/>\nof Judicature at Bombay, whereby the High Court summarily dismissed an<br \/>\napplication made under Section 66(2) of the Indian Income tax Act, 1922,<br \/>\nrequiring the Income-tax Appellate Tribunal to state a case and refer to it<br \/>\nthe questions of law said by the appellant to arise out of the order of the<br \/>\nTribunal The appellant is a Hindu undivided family, comprised of Dhirajlal<br \/>\nand his two brothers Hiralal and Kirtilal, Dhirajlal being the karta of the<br \/>\nfamily. Girdharlal Trikamlal who was the father of Dhirajlal, Hiralal and<br \/>\nKirtilal, was the head of the joint Hindu family before his death on 26th<br \/>\nJuly, 1945. During his lifetime he and one of his sons Dhirajlal were also<br \/>\ncarrying on business separately in their firm name Girdharlal Trikamlal &amp;<br \/>\nCo., as dealers in stocks and shares. This firm was dissolved on the death<br \/>\nof Girdharlal and a new firm comprised of Dhirajlal and his younger brother<br \/>\nHiralal was formed with the object of taking over the business formerly<br \/>\ncarried on by Messrs. Girdharlal Trikamlal &amp; Co. Girdharlal had an account<br \/>\nwith the firm of Girdharlal Trikamlal &amp; Co. and on the date of his death<br \/>\nthis account had a credit balance of Rs. 25, 31, 999. The firm Girdharlal<br \/>\nTrikamlal &amp; Co. at that moment had shares of the value of Rs. 23, 60, 000<br \/>\napproximately as part of their total assets. On the death of Girdharlal,<br \/>\nhis three sons and his widow clearly became entitled to the amount that<br \/>\nstood to his credit in the firm Girdharlal Trikamlal &amp; Co. and by an<br \/>\narrangement made after his death the Hindu undivided family got in July,<br \/>\n1942, shares of the value of Rs. 18, 34, 586 from the firm towards payment<br \/>\nof its liability to the Hindu undivided family as part of the inheritance<br \/>\nof Girdharlal and for the balance the Hindu undivided family was shown as<br \/>\ncreditor of the new firm. The shares that were handed over were valued at<br \/>\nthe market price. The Hindu undivided family thus in its status as such<br \/>\nbecame the owner of those shares. It is common ground that the family in<br \/>\nthat status antecedent to that date was not doing any business in stocks or<br \/>\nsharesThe Hindu undivided family having obtained the shares, it sold some<br \/>\nof the shares in the financial year 1943-44 and made a profit of Rs. 1, 42,<br \/>\n025 in the assessment year 1944-45. The Income-tax Officer during that year<br \/>\nincluded the profit made by sale of shares in the assessment of the Hindu<br \/>\nundivided family by arriving at the following finding :&#8211;\n<\/p>\n<blockquote><p>    &#8220;The undivided Hindu family continued to do the share business and<br \/>\n    purchased shares worth Rs. 3, 00, 460 during the account years 1942-43<br \/>\n    and 1943-44. What the assessee got from their father Mr. Girdharlal<br \/>\n    Trikamlal was converted by them into trading capital or, in other word<br \/>\n    they had converted their inheritance into the stock-in-trade. The fact<br \/>\n    that they had been purchasing other shares appears to point to this<br \/>\n    conclusion only. In these circumstances I include the profit of Rs. 1,<br \/>\n    42, 025 in the assessment.&#8221;\n<\/p><\/blockquote>\n<p>The appellant combated this position before the Appellate Assistant<br \/>\nCommissioner and contended that the family was not doing any business in<br \/>\nstocks and shares. On the other hand. it was only unloading the shares<br \/>\nwhich had come to it on the death of Girdharlal Trikamlal and was trying to<br \/>\nconvert them into cash, and whatever shares were purchased were purchased<br \/>\nby way of investment. The Appellate Assistant Commissioner accepted this<br \/>\ncontention and gave a reduction of Rs. 1, 42, 025 in the income as<br \/>\nassessed. He said as follows :&#8211;\n<\/p>\n<blockquote><p>    &#8220;Thus on facts before me I hold that the transactions in shares are by<br \/>\n    way of change in investment and not business dealings. Hence the profit<br \/>\n    is capital accretion and not business profit. Thus the same is not<br \/>\n    liable to assessment.&#8221;\n<\/p><\/blockquote>\n<p>The Commissioner of Income-tax preferred an appeal against this order and<br \/>\nwith success. The Tribunal by its order dated the 1st August, 1951, allowed<br \/>\nthe appeal and restored the order of the Income-tax Officer. It held that<br \/>\nthe transfer of shares of the value of Rs. 18, 34, 586 by the new firm to<br \/>\nthe Hindu undivided family was a device to evade income-tax. After<br \/>\nexamining the purchases and sales of shares by the Hindu undivided family<br \/>\nduring the years 1942, 1943, 1944 and 1945, the Tribunal came to the<br \/>\nconclusion that the moving spirit in the new firm being Dhirajlal who was<br \/>\nalso the karta of the Hindu undivided family, knowing the conditions<br \/>\nobtaining in the market effected the said transactions of the transfer of<br \/>\nshares to enable the Hindu undivided family to realize the profits. The<br \/>\nTribunal concluded its decision with the following observations :&#8211;\n<\/p>\n<blockquote><p>    &#8220;Shares of the value of Rs. 18 lakhs odd were transferred, one might<br \/>\n    say, by a dealer in shares to himself in another capacity. There was<br \/>\n    absolutely no reason why the shares should have been transferred to the<br \/>\n    Hindu undivided family. It has also not been pointed out why the Hindu<br \/>\n    undivided family found it necessary to effect sales of a large number<br \/>\n    of shares in the financial years 1943-44 and 1944-45. It has also not<br \/>\n    been shown why the Hindu undivided family should have purchased shares<br \/>\n    of the value of over Rs. 2 lakhs between 1st August, 1942, and 1st<br \/>\n    March, 1943. We have examined the frequencies of the sales in the<br \/>\n    financial year 1943-44. Shares were sold in July, August, October,<br \/>\n    December, January, February and March. The irresistible inference<br \/>\n    appears to be that from the very start the intention of Dhirajlal both<br \/>\n    as a transferor and as a transferee was to deal in these shares.&#8221;\n<\/p><\/blockquote>\n<p>The appellant made an application to the Tribunal for statement of the case<br \/>\nand for a reference of questions of law arising out of the order of the<br \/>\nTribunal to the High Court. By its order dated the 23rd November, 1951, the<br \/>\nTribunal disallowed the application on the ground that the question whether<br \/>\nor not the Hindu undivided family carried on business in respect of the<br \/>\nshares transferred to it by the firm and in the shares purchased by it, is<br \/>\na question of fact and that no question of law arose out of the findings of<br \/>\nthe Tribunal and that from the very start the intention of Dhirajlal both<br \/>\nas a transferor and transferee was to deal in these shares. Dissatisfied<br \/>\nwith the order of the Tribunal, the appellant made an application to the<br \/>\nHigh Court under Section 66(2) for a direction to the Tribunal to state a<br \/>\ncase and to refer to it the following questions of law :&#8211;\n<\/p>\n<p>1. Whether on the facts and circumstances of the case the assessee was<br \/>\ndoing business in shares in the account year ; or<\/p>\n<p>2. Whether there is any material on record on the basis of which it could<br \/>\nbe held that the assessee was doing the business in shares in the account<br \/>\nyear<\/p>\n<p>As already pointed out, the High Court summarily dismissed the application,<br \/>\npresumably on the ground that in its opinion no question of law arose out<br \/>\nof the order of the Tribunal. On an application being made to this Court<br \/>\nunder the provisions of Article 136 of the Constitution, leave to appeal<br \/>\nagainst this order was granted<\/p>\n<p>The question whether or not the Hindu undivided family was doing business<br \/>\nin shares transferred to it by the firm is undoubtedly a question of fact<br \/>\nbut if the court of fact, whose decision on a question of fact is final,<br \/>\narrives at this decision by considering material which is irrelevant to the<br \/>\nenquiry, or by considering material which is partly relevant and partly<br \/>\nirrelevant, or bases its decision partly on conjectures, surmises and<br \/>\nsuspicions, and partly on evidence, then in such a situation clearly an<br \/>\nissue of law arises. It is apparent from the following quotation from the<br \/>\njudgment of the Tribunal that not only was its approach to the question<br \/>\nraised before it tainted with suspicion, but it took into consideration a<br \/>\nnumber of circumstances based purely on conjectures and surmises and for<br \/>\nwhich there was not a scintilla of evidence on the record. This is what was<br \/>\nsaid by it :&#8211;\n<\/p>\n<blockquote><p>    &#8220;It appears to us that this transfer was effected with the object of<br \/>\n    evading income-tax, if it could be done so legally. If the shares had<br \/>\n    remained with the new firm, and if sales had been effected, the profits<br \/>\n    would have been liable to tax. The very fact that shares were<br \/>\n    transferred, and that also a substantial holding of the firm, indicates<br \/>\n    conclusively that the object of the transfer was to evade income-tax,<br \/>\n    if possible. The Hindu undivided family, it strikes us did not take the<br \/>\n    shares as the return of its capital. The Hindu undivided family knew,<br \/>\n    when the shares were transferred, what the object underlying the<br \/>\n    transfer was. If these shares had remained with the Hindu undivided<br \/>\n    family for a considerable time, one might very well accept the<br \/>\n    proposition that the Hindu undivided family took the shares as the<br \/>\n    return of its capital. The Hindu undivided family, however, did not<br \/>\n    keep the shares for a very long period. We have already indicated that<br \/>\n    no shares were sold between 1st August, 1942, and 31st March, 1943.<br \/>\n    Between 22nd July, 1942, and 31st March, 1944, shares of 16 companies<br \/>\n    were sold for Rs. 3, 67, 420. Some of the shares sold were out of the<br \/>\n    shares purchased between 1st August, 1942, and 31st March, 1943,<br \/>\n    &#8230;&#8230;. It goes without saving that the moving spirit in the new firm<br \/>\n    was Dhirajlal, being the elder brother, and the moving spirit in the<br \/>\n    Hindu undivided family would also be Dhirajlal. He in his capacity as<br \/>\n    the transferor and in his capacity as the transferee was fully aware of<br \/>\n    the conditions obtaining in the share market. Prices were rising and<br \/>\n    were likely to rise on account of war.&#8221;\n<\/p><\/blockquote>\n<p>The learned Attorney-General frankly conceded that it could not be denied<br \/>\nthat to a certain extent the Tribunal had drawn upon its own imagination<br \/>\nand had made use of a number of surmises and conjectures in reaching its<br \/>\nresult. He, however, contended that eliminating the irrelevant material<br \/>\nemployed by the Tribunal in arriving at its conclusion, there was<br \/>\nsufficient material on which the finding of fact could be supported. In our<br \/>\nopinion, this contention is not well founded. It is well established that<br \/>\nwhen a court of fact acts on material, partly relevant and partly<br \/>\nirrelevant, it is impossible to say to what extent the mind of the court<br \/>\nwas affected by the irrelevant material used by it in arriving at its<br \/>\nfinding. Such a finding is vitiated because of the use of inadmissible<br \/>\nmaterial and thereby an issue of law arises<\/p>\n<p>For the reasons given above we are of the opinion that both the Tribunal<br \/>\nand the High Court were in error in the view that no issue of law arose in<br \/>\nthe case and that the Tribunal could not be called upon to state a case and<br \/>\nto refer to the High Court any issue of law. The two questions framed by<br \/>\nthe appellant and which he wanted the High Court to ask the Tribunal to<br \/>\nrefer to it are comprehensive enough to embrace the issue of law that, in<br \/>\nour opinion, arises out of the order of the Tribunal. But we think that it<br \/>\nwould clarify the position if these two questions were re-stated in the<br \/>\nfollowing form :&#8211;\n<\/p>\n<blockquote><p>    &#8220;Whether the finding of the Tribunal is not vitiated by reason of its<br \/>\n    having relied upon suspicions and surmises not supported by any<br \/>\n    evidence on the record or upon partly inadmissible material ?&#8221;\n<\/p><\/blockquote>\n<p>In the result we allow this appeal, set aside the order of the High Court<br \/>\ndismissing the application of the appellant under Section 66(2) of the<br \/>\nIndian Income-Tax Act, 1922 , and remand the case to the High Court with<br \/>\nthe direction that it should ask the Tribunal to state a case and to refer<br \/>\nto it the following question of law :&#8211;\n<\/p>\n<blockquote><p>    &#8220;Whether the finding of the Tribunal is not vitiated by reason of its<br \/>\n    having relied upon suspicions and surmises not supported by any<br \/>\n    evidence on the record or upon partly inadmissible material ?&#8221;\n<\/p><\/blockquote>\n<p>The costs will abide the result.\n<\/p>\n<p>Appeal allowed.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Supreme Court of India Dhirajlal Girdharilal vs C.I.T. Bombay on 25 October, 1954 Author: M C Mahajan Bench: M.C. Mahajan (Cj), S.R. Das, G. Hasan, N. H. Bhagwati, T.L.V. Aiyyar CASE NO.: Appeal (civil) 246 of 1953 PETITIONER: DHIRAJLAL GIRDHARILAL RESPONDENT: C.I.T. BOMBAY DATE OF JUDGMENT: 25\/10\/1954 BENCH: M.C. MAHAJAN (CJ) &amp; S.R. DAS &amp; [&hellip;]<\/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-245005","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v27.3 - https:\/\/yoast.com\/product\/yoast-seo-wordpress\/ -->\n<title>Dhirajlal Girdharilal vs C.I.T. 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