Raja Bahadur Kamakhya Narain Singh v. Commissioner Of Income.tax, Bihar And Orissa

A RAJA BAHADUR KAMAKHYA NARAIN SINGH COMMISSIONER OF INCOME.TAX, BIHAR AND ORISSA September 1, 1969 (J. NI. SHELAT AND C. A. VAIDJALINGAl>I, JJ.] Capitlil or Jnco1ne-Purchase and sale of gold and shares-Principles far deciding whether profit on transactinns is revenue or capital receipl-Question is of 1nixed fact and law-High Court in reference not bctrred jru1n going into findi11gs of Tribunal 011 such question on the ground th(lt it iJ one of fact and therefore final. c The assessec inherited a vast cst:.1te c·on'iisting of ngricl1\tural and othei land as also Government sc:urities worth Rs. 40 Ines. In 1937 he attained majority and control of the estate from the Cvurt of Wurds. In the account· ing year 1938-39 he sold some of those smtritics at a profit. Thereafter he opened on account i11 the Imperial llnnk of India i11 the name of his wile nnd called it "nccornlt of 48 lacs l1011ting in the shat'c market.'' In Sopt,m-ber 1939 he purchmd shares worth Rs. 34.14 Ines out of the said fund but sold them, •A•in at a profit in the venrs 19;9, 1940 ond 1941. The profits on the said snles of share• were •uhjectcd to tax by the I ncomc-i.1x Offie<r in lhc yenrs 1939-40, 1940-41 and 1941-42. The 'frihunal however held that the ""essee was not ·n denier in shares nnd held th•! profits not to be taxable. Dctwccn lune and Novcmb·or 1940 the usscsscc purcham1 gold for Rs. 28,47,380/- from out of the sale prooocds of the aforcs:iid shares. This gold was sold nt n profit in the accounting periodi:i rel,~vnnt to the 1945-46 and 1946-47 r:s'iessment years. \Vith th<.:! sale proceeds certain shares including 7,025 shares of Karanpura Dcvclopn1oent Co. Ltd. E were purchased, most of \Vhich were sold at a profit. Certain VichJrv Bonds were purchased ·and resold within two 1nonthi;;, The lncon1c-t:ix Officer subjected the profits from the sales of gold an<l Karanpur shares to tax in the assessment years 1945-46 and 1946-47. The Tribunal on considering the whole pattern of transactions from 1938 onwards came to the 1conclusion that the said profits were rightly taxed. The High Court upheld the view of the Tribunal holding inter alia, that the findings were of F fact and not arrived at without evidence so that no interference \Vas warranted in reference proceedings. The. assessee appealed. HELD : ( 1) When' a transaction is not in the ordinary lines 'of an assessee's business the facts must be properly assessed to discover whether it was in the nature of trade. The test often applied is-has the assessee made his shares and securities the stock-in-trade of a business? [171 G; 172 HJ (ii) Since in the present case the Tribunal had the advantage, of examin-ing the assessee's tranr.1.ctions during the whole period i.e. right from 1938-39 to 1944-45 and thus had more comprehensive picture of all the transactions, there would be no bar to its coming to a conclusion different from that arrived at in the ear1ier years, if the acts <1nd conduct of the assessee taken as a whole throughciut the period pointed to a different conclusion. [174 A-BJ (iii) On the facts and circumstances of the case, however the finding of the Tribunal, concurred in by the High Court, that the transactions in question were in the, nature of trading transactions, was not justified. [174 C-D] (a) It is a notorious fact that in 1940 the fortunes of the allies were none too bright. The conversion by the assessee of his entire share holdin~ into gold in that year was consistent with his case that he did so because of the nervousness engenCered by ·the breaking out of the war, the initial German victories, and the fall of France. The fact that the assessee did not invest all his cash would not mean, as the Tribunal thought, that his case about the purchases of gold was not correct. [174 D-FJ TIT TEST HrarEaT aera fag qraet wee, fase We Tet (Raja Bahadur Kamakhya Narain Singh (1 faaeaz, 1969) (sato Fo GAo AAA We eto To aatemq) —aE fafaaawey (gait at ata ath ite Bret at ea AEfata & fac fagra fe aat aenagrel IT ATA ATA BAT Tata fA —Aygeet qua nite fafa at fafa a4 a—da saa ot afar qua nite fafa at fafa a4 a—da saa ot afar nite fafa at fafa a4 a—da saa ot afar fafa at fafa a4 a—da saa ot afar at fafa a4 a—da saa ot afar fafa a4 a—da saa ot afar a4 a—da saa ot afar a—da saa ot afar saa ot afar ot afar afar[[%][ froma][ oz]][[ froma][ oz]][[ oz]][ ——]Sard TAH far fret A Sea AATAT IZ SA ANT TT HE Ts ANT geet qua nite fafa at fafa a4 a—da saa ot afar qua nite fafa at fafa a4 a—da saa ot afar nite fafa at fafa a4 a—da saa ot afar fafa at fafa a4 a—da saa ot afar at fafa a4 a—da saa ot afar fafa a4 a—da saa ot afar a4 a—da saa ot afar a—da saa ot afar saa ot afar ot afar afar[[%][ froma][ oz]][[ froma][ oz]][[ oz]][ ——] Bhs ay Ge Ter FT HET ait gafey afer a | ~ Gqatfedt at facta F aga agt aeaar faett frat ais AV WA aft me ara 40 are BIT H ger Bt aaa sherghaat ft af 11937 8 ae areataat mar ait sa gfacrer afaaem & aesar aT fraeaa at STSt Bl Tar | Tarag 1938-39 Haut zai B ga sfayfedy a ara qe aa fewaeqeay Tay AT Tet FATA H erdferr aa ars efeeat FEF ara@rat att SA BAT aT H 48 ara VAT HT aT ata’ (accountof 48dacs floating in the share market) ara feat | faaras, 1939 4 om fafa% & sax 34.14 are waa ger F TAT Ue fac sic far saat aq1939,1940 ae 1941 H ara Te Sa fear Mat F TAT faa 1 Tl ATA gar Vaax armat wfaaret F AT 1939-40, 1940-41 ate 1941-42 H BT aaTAT |farg afaaea > ag afafratfca Pra[fe][ fratfedh][ gael,][ er][ aatarat][ al][ &] oosTATeAT ATTA fag Fo MART IAA [FATo ATT] siz ag wt afafaatfer fear feart verte adi f1 ga WIT aataz, 1940os fe fauifedt & oem Ratt F fess arrat FS -28,47,380 eat ar AATadtat | ae arat Frazer at 1945-46 att 1946-47 FT YaTT wat Braraferate ara ac aa feo aay| oa faa arma} & gy Rae ad ay feat eTATTfeqaqiwe seat fafaes B 7,025 Hat at afeafaa & ate sak a atest.arr ae aa faq ae 9g feast ares HH aAT ae ae TEA TAF WaTga: aa fear var| maRt afaard 4 aA AIR aTagT Hae feat a eTara ot faaizer ag 1945-46 HIX 1946-47 Fae aaa1 afxae A1938fo .° Rava & daa F ays qzq oz faare wa R eng ae farsesfanrar fe saa UTat TT aT ST aTIAT TAT eae SH Fl GT TAIT aofanua at gfe we a ate ea otal e aaa ag dt afatraite. frat fe frost aedf oz aretfea ar ate ag ater &| far aet fratatTarat, ave fase sia FE seaaT BTA A HraRTHAT TT ay| fastfedta adie at7|_: afafratfer—(i) wa are aeragre faatfedl F BTRETX mY STATgata aT a daa ag argu Hea % far aeal ar sist eT q frafeor Pta4r-aifar fe aor ag aemaygre carare at safe BT ge| Ta: st Hata scars artsagas fe—am fratfeddF aot Fatt AIX sfayfadt a BIRT FTsaraTy tary TaATATZC:_ Sik) qfe sega aaa a afeacg at aged ararafa Fata wait1938-39 & Bax 1944-45 aw. gu fasifedt F aeaagtt sl Thar sw atqfaar area oft atx ge cart afaHeT H Ta TAY SerARI FT afan faetasara at, mata afapey & fae sa fasne a fred fasag fara 3 ars dev.adit dt ot gaa gd frat act & arae F frarer ot, afe vaaq‘aravafa 3 dha fratfedt ® aaa arat atc ara& fires fread frsaat|Co,al |(iii) faeg aay B geal whe ofefeafeal & arnt oe Tea HaTATAAgir wgafa sea ufaacy ar ag fread fe seama doragre aataries eqagrdl at safer8, errata ret aT| (=) ag aafafer aca g fe fra Qatar wfacr aga Usa wet aTsage afratfectt aren godt arqat Fax anfear ar aAHR araftada Taaaa & aga ar fe sat tat za aren fear fe st ge fas a0, 340 eae eararea Faeia afar [1970] 3 BHo fo qo”ro arian ia Prot ate aie Brat ® are fac gear a ae oti ca gap & fr fratfedt 2 aad are azz can fafafaa wet at at, ae afata aalvat &, star ael a fe afaaca, ar frac or fe aR ere| at F aa TerOSAT The Tribunal also failed to give due significanoe to the fact that the assessee who started with the plan of getting at least net 7% yield, put a very large part of his funds into gold, an altogether sterile security, and retained it for 4 year!'l The price of gold' began to ris~ in 1941 and was at its peak in 1943. The fact that the assessee did not sell his gold then but only in October 1944 when the. price had fallen showed that it was only after the fortunes of war had turned in favour of the allies and con-fidence restored that he felt it safe to invest his money in income-bearing securities. The further fact that he sold practically the whole of his stock of gold in October 1944 lnstead of reselling it bit by bit after the price was rising since 1942 was inconsistent with the hypothesis -that the object with which the gold was purchased was to trade in it. [174 G-H; 175 A-DJ (b) The fact that the account in the Imperial Bank opened in 1939 was called "Rs. 48 lacs floating in the share market" was given undue significance by the Tribunal. Properly viewed it only meant that the assessee wanted to set apart this fund for tr,ansactions in shares and securi-ties and not mix up his other capital and the income arising from his estate. [175 D-EJ ( c) The sale of the Victory Bonds within two months of their purchase \\-'Ould not invest the transaction with the stamp of trade or busine~ for they were only purchased to show to the authorities that his estate had made a contribution to the war effort. [175 E-Gl (d) The Karanpur shares were purchased by the assessee with a vie,w to 1tetting control over the company's management by procuring 51 % of its total shares. When that plan failed he sold these sh~res. In these circumstances the transaction could not be considered to be on revenue account. [175 G-H; 176 DJ Kishan Pramd & Co. Ltd. v. C.i.T., (1955) 27 l.T.R. 49 and C.l.T. v. National Finance Ltd. ( 1962) 44 J.T.R. 788, applied. ( e) The expression 'advent~re in the nature of trade' implies the exist~ ence of certain elements in the transactions which in Jaw would inTest them with the character of trade or business. The question the.refore \Vhether a particular transaction is an adventure in the nature of trade is a mixed question of law and fact and the court can re,view the Tribunal's finding thereon. Therefore in the present case the ·High Court was wrong in treating the Tribunal's decision as a finding of fact and refusing to interfere on that ground. [171 A-CJ Venkataswami Naidu &: Co. v. C.l.T., (1959) 35 I.T.R. 594, 603, 604 and Liquidators of Pursa Ltd. v. C.I.T., (1954) 25 I.T.R. 265, referred to. CIVIL APPELLATE JURISDICTION : Civil Appeals Nos. 481 and 482 of 1966. Appeals 'by special leave from the judgment and order, dated April 15, 1963 of the Patna High Court in Misc. Judicial Cases Nos. 342 and 346 of 1954. A S. T. Desai and D. N. Mukherjee, for the appellant (in both the appeals) . Jagadish Swarup, Solicitor-General, S. Sachthey and B. D. Sharma, for the respondent appeals) Solicitor-General, S. K. Aiyar, R. N. (in both the 'Ille Judgme.nt of the Court was delivered by 340 |ATAU ga Tey aT AT BeTE ga Tey aT AT BeTE Tey aT AT BeTE aT AT BeTE BeTENea BA A aaa car fe fralhet BA A aaa car fe fralhet aaa car fe fralhet car fe fralhet fe fralhet fralhetA Gat aa tar 7 sfeaa sorta area aaa at aiaat gery a a, amt aa tar 7 sfeaa sorta area aaa at aiaat gery a a, amt tar 7 sfeaa sorta area aaa at aiaat gery a a, amt 7 sfeaa sorta area aaa at aiaat gery a a, amt sfeaa sorta area aaa at aiaat gery a a, amt area aaa at aiaat gery a a, amt aaa at aiaat gery a a, amt at aiaat gery a a, amt gery a a, amt a a, amt a, amt amt gS a 1943 Hagen dar ae gga aE | ee aia h 1943 Hagen dar ae gga aE | ee aia h Hagen dar ae gga aE | ee aia h dar ae gga aE | ee aia h ae gga aE | ee aia h gga aE | ee aia h aE | ee aia h | ee aia h ee aia h aia h ear atat aa aar, afer ga WIT, 1944 # Far aq at ataa faz 7 of, atat aa aar, afer ga WIT, 1944 # Far aq at ataa faz 7 of, aa aar, afer ga WIT, 1944 # Far aq at ataa faz 7 of, aar, afer ga WIT, 1944 # Far aq at ataa faz 7 of, afer ga WIT, 1944 # Far aq at ataa faz 7 of, ga WIT, 1944 # Far aq at ataa faz 7 of, WIT, 1944 # Far aq at ataa faz 7 of, 1944 # Far aq at ataa faz 7 of, # Far aq at ataa faz 7 of, Far aq at ataa faz 7 of, aq at ataa faz 7 of, at ataa faz 7 of, ataa faz 7 of, faz 7 of, 7 of, of, Shelat, J. These two appeals, under special leave, arise from two References to the High Court of Patna under s. 66(2) of the Income Tax Act, 1922 and relate to the assessment years 1945-46 and 1947. In the first appeal, the question arising for deter-c mination is whether, on the facts and circumstances of the case, the surplus receipt of Rs. 13,43,469/-, realised as a result of the sale of gold, is assessable as income, or profits or gains for the assessment year 1945-46 under s. 4(3) (vii) of the Acl. In the 2nd appeal, Jwo questions arise for determination; one relates to the surplus receipt of Rs. 33,481/- arising out of the sale of some more gold, and the second relates to the receipt of Rs. 88,522/- realised D by tlie assessee as a receipt as a result of sale of certain shares. All the three questions raise the common problem whether the said tr?.nsactions in gold and shares were by way of realisation of investment or were adventures in the nature of trade or business. The assessee was at all material times a landholder deriving E large income from agriculture, royalties of minerals and income from forests forming part of his estate. Prior to 1937, when, he was a minor, his estate was under the management of a Court of Wards. · On attaining majority, the estate, which included Government securities of the value of about Rs. 40 lacs, was hand-ed over to him on August 19, 1937. During tlie account year 1938-39 he sold the whole lot of these securities and realised F Rs. 44,25,088/-, the sale thus resulting in an excess of Rs. 4,55,305/-. This excess amount was assessed as profit by the in-come-tax officer for the assessment year 1939-40. But on appeal against the assessment order, the Appellate Tribu,n'al set side that ?rder on a finding that the said sale was by way of a change in mvestment, and therefore, was not a transaction in the nature of G trade or _business. On March 23, 1939, the assessee opened an account m the Imperial Bank of India initially with Rs. 46 lacs which included the said sale proceeds of Rs. 44 lacs and odd and to which on March 27, 1939 he added Rs. 2.60 lacs. The account was opened in the name of his wi.fe and was called "Account of R~. 48 lacs floating in the share market". In September 1939, the H assessee purchased shares and debentures of the value of Rs. 34.14 lacs ~rom out of the funds in the said account. He, however, sold certam shares for Rs. 5,75,723/- in October 1939 and then the rest of them in 1940 and 1941 realising Rs. 29,S8,677/-and «mer fe 1942 & ans aga TAH araae A vad as-G3 a BT ga: 1942 & ans aga TAH araae A vad as-G3 a BT ga: & ans aga TAH araae A vad as-G3 a BT ga: ans aga TAH araae A vad as-G3 a BT ga: aga TAH araae A vad as-G3 a BT ga: TAH araae A vad as-G3 a BT ga: araae A vad as-G3 a BT ga: A vad as-G3 a BT ga: vad as-G3 a BT ga: as-G3 a BT ga: a BT ga: BT ga: ga: —(S) a8 ea fe 1939 F eather dat Gat ara B48 ate wad arIG Slat, ATTFt arat @ar Ta, S43 afrwey gre wataH ageT feat TATafaa sare & fare ae at vad Raa mat afasa dara Pe frettedau fafa a1 tad att sfayfaal & fae gan & wear agarmeaar ate sa ATT Tot ae agar & ala are ara wt faatar tet ATeaAT aTt (1) fad aretBaaAaa R waz srl fase ary F gtaemast Fz eqrat aT aTLaTe a aT agt a onet, aaife faadt aressaiftarfeayt at Rast ag feat & few qa me's fe saat artar A wt ggsrtaré # afara frat 2 ||o (a) faite& FUATU WaT ga gfe # aie % fe seat eat hatte 51 ohare hae greg wh wae gar qe faaeam gra fearWIE| Tae agNea ane gt Te aa vax va dad Aas fear 1 sat ofefen faaH eeragre Hl are & RB ay arar wr away ar| frat saz Qs art fefate garT arTEe maga (Kishan Prasad & Co, Ltd. Vs. Commissioner.of Income-tax), (1955) 27 HT¥o ao AITo 49|At wet MAI aT Anas sarafeeds(Commissioner ofIncome-tax Vs. National Finance Ltd.), (1962) 44 argo do aTto 788;arg far a|..oe (=) ‘carat st eft Fr srw, (adventure in the nature of trade)Te a dena H afore seat a faaartar at wre iar 2, faad fafir atafer & & deaagre caray at areata safe Ba HATwae ag yerfe age até fafince deaaere earnt at yah ar tea é, faf ate aa arfafaat seat 2 att ga ox fray ae afer FH fasny eT Faery SafaaartBC AHAT Fl HALT Tega aaa A sey eqraraa a alana ® fafesaa at gerqt ararfea ews ara HT AIT Te AGI Te yaw SCIAT HUA J sere HT at a a|| aera at a a 'aRecaTAY AAs Ves Heal AAA wraTHTatgat_ (Venkataswami_ Naidu & Co. Vs, Commissioner of Income-tax), (1959) 35 a1$0 go aIzo594, 603, 603,604AIRgratfefaésF aarae aay wat oaaa. J /* (Liquidators of Purasa Ltd. ¥s. Commissioner of Income-tax) ; (1954)FT95 ato ao aI<o 265 sfafeceomg)_oSfafas adic afaatizat: 1966 #1 do 481 ale 482 art fafas aad|1954 % Ho 342 AIX 346 ara saat catfam aradt #gear geqrarataa & arte 15 asta, 1963 area frata ate ata ® faeg fade saga-Mat at re ale|Be_ 594, 603, 603, adtatat a att a‘aaa. Tao eto are At go Ute Gast . * gemit at ste a wast THe FBT, THe Ho AIL, AILo UeGIs AX Fo SoWat arate ar frat eararfarfa So uAe stata fear| ematfaate awa + at wate seem faq Caz, 1922 at are 66(2)B atte gear geeararaa at fee qe at fadat * fees fare saraa Fax at Tee Alt fagizay 236 geaaH arate facia afaet = [1970] 33H fro ae” ay 1945-46 atx 1946-47 Baraka Fi saa ata A maar F fag atGIT BEIT FAT Ss IS AS g Fe aa araa & aval ate afefeafaat & Arsiz gzaia & fara & srct 13,43,469 aaa at oafaare ofa tae Bt ater 4(3) (vii)& ada fate ag 1945-46 ® fav ara ar ara ar afaara & eT A frataegad ada F aaereor H fre at oat SIT ala & fay a wa faitegra a3 ae ga ate ofan aH feet s says 33,421 eat at aftsifes & arafeara & oe gae sah are afasa Hatfase F aTNeTeTget $8,522 ea at orfear & aratedF1 aat es met A oag aa MAE aat es met A oag aa MAE es met A oag aa MAE met A oag aa MAE A oag aa MAE oag aa MAE aa MAE MAE | att 8 fe aar aA ate Had FH sae aeaaare fafrars aT gif 8 fe aar aA ate Had FH sae aeaaare fafrars aT gif aar aA ate Had FH sae aeaaare fafrars aT gif aA ate Had FH sae aeaaare fafrars aT gif ate Had FH sae aeaaare fafrars aT gif Had FH sae aeaaare fafrars aT gif FH sae aeaaare fafrars aT gif sae aeaaare fafrars aT gif aeaaare fafrars aT gif fafrars aT gif aT gif gifPaw me & ar F sarare ar Tare HT THTMTA A | F1 aat es met A oag aa MAE aat es met A oag aa MAE es met A oag aa MAE met A oag aa MAE A oag aa MAE oag aa MAE aa MAE MAE | Rs. 64,201/- respectively. The first sale fetched a profit of Rs. 1,17,064/- the second a profit of Rs. 25;133 a:::1 the third a loss of Rs. 1,642/-. The income-tax officer brought to tax the two surpluses in the assessments for the assessment years 1940-41 and 1941-42. But the department was again unsuccessful as the Tri-bunal once again held, on the strength of the correspondence which had passed between the assessee, his bankers au:ld his brokers in Calcutta, that the only possible conclusion emerging from that correspondence was that the assessee's intention was not to deal in shares and debentures, a.nd that the said transactions were a mer~ change in investment carried out of a single scheme of earn-ing a better yield from investments. The Tribunal's orders in respect of these assessments for the assessment years 1939-40 to 1941-42 were made part of the Statement of Case filed by the Tribunal before the High Court in the present References. Between June 28, 1940 and November 9, 1940 the assessee purchased 68,109 tolas of gold for Rs. 28,47,380/- from out of the sale proceeds of the said shares. The gold so purchased was kept in his family vaults at Padma, the seat of his estate, for nearly 4 years. Between October 9, 1944 and October 20, 1944, he disposed of the bulk of the goltl, i.e. 55,494 tolas, for Rs. 36,80,174/-, the sale resulting in a surplus of Rs. 13,43,469/-, which is the subject-matter of the first appeal. The remaining quantity of gold was sold 011 October 19; 1945, and that sale brought him an excess of Rs. 33,481/-, which is part of the subject-matter of the second appeal. In respect of these two surplus amounts, the assessee contend-ed that they were the result of a change in investment and could not be said to be transactions in the l!lature of trade or business. His ca~e was that neither the Government securities, nor the shares and debentures purchased out of their sale proceeds, nor the gold were sold and purchased by way of dealing in them, that. at no .time they became his stock-in-trade for any business or adventures in the nature of trade or business therein, that the transactions were mere conversions from one investment to an-other, depend\ng upon the circumstances which prevailed during the respective periods and that the sale of gold in 1944 and 1945 was occasioned partly due to the tide . in the second world war turning in favour -0{ the allies and partly due (a) to his having to pay Rs. 7 lacs by way of income-tax, (b) expenses for the marriage of his younger brother, ( c) for payment of Rs. 6 lacs debt to one Gupta and ( d) for purchase of Victory Bonds worth Rs. 14 lacs and odd at the instance of the Government authorities as contribution of his estate to the war effort. The Tribunal rejected the case that gold had been sold for the reo.sons given by the assessee or as a change in· investment and A held that : (l) conversion of shares into gold was not due to any panic resulting from the war, (2) that there was no pressing necessity for the sale of gold as alleged by him, (3) that Victory Bonds were not by way of any war effort since the assessee sold them away within a short time after their purchase, and ( 4) that the sale proceeds of gold were utilised in purchasing shares for which he borrowed an additional amount of Rs. 5.10 lacs i.n B 1945-46 against· gold. In ihis view the Tribunal confinned the l.T.0.'s decision that the two excess amounts were liable to income tax in the two assessment years. oder att 8 fe aar aA ate Had FH sae aeaaare fafrars aT gif 8 fe aar aA ate Had FH sae aeaaare fafrars aT gif aar aA ate Had FH sae aeaaare fafrars aT gif aA ate Had FH sae aeaaare fafrars aT gif ate Had FH sae aeaaare fafrars aT gif Had FH sae aeaaare fafrars aT gif FH sae aeaaare fafrars aT gif sae aeaaare fafrars aT gif aeaaare fafrars aT gif fafrars aT gif aT gif gif "fraffedt att atten aaal ox qarea at att ag Ble Saga ATT ATTHT Et A, fast carfaer Be sina 4, ot saat aeqar ear a, aTSeer HT TEL IT 1 BT 1937 F Ys HH aE AMCTTT AT, GARY ALT sfaqterafar & carats a | TTA eIa Te ATT, fart arat 40 are ett& yea at aearet sfrgfaat afeatert off, 19 ama, 1937 ar va ata et asrar at 1938-39 & aera cae aa ofryfadl ar meget ate aa feat AIT44,25,088 waa set faut za Tart ga faw7 % 444,305 waa afte medguiga afan wr ar araae afaard 4 fratea ay 1939-40 % farara ® eq tt fratem fears fag faateq aaa % fare adla er Iada afarcoca fread at ga aa at aad Ft feat fe saa farfafagra F ofeada HA FH HACTST Al MATT FF SATA AT HTRATT at wHtaHT MeTaSle TST AT| 23ard, 1939 a1 faaifedd & srxewa: 46 are eat aariifers ae are gfosar Howa erat ata frat waa fw F ATTA FATA44 ae war afeafaa & ale 27 ard, 1939 at yaa sat 2.60 ate waae pu fea1 aay saat Tet F ara A Gar TAT AT AIT ZA ‘NAT ATHIT F48 ara eTd Br aly qian’ are feat warfaaraz, 1939 8 faaifedt | saTqa % at fafa FF 34-14 are wt yer Hae we fedat aefagyar qagaz,. 1939 ¥ Hq ax 5,75,723 waa 4H ae far are fet aral eazta} aut: 1940 AIX 1941 F 29,58,677 wat wie 64,201 wat H Sa fears gamfast & 1,17,064 wad ar art gat wie facta fae25,133 ea a aeeit farmer & 1,642 wae at aif ge1 aaa aaa A eA atat afaarat oz ah 1940-41 ate 1941-42 Fae fratfer fears freg frat fax 1940-41 ate 1941-42 Fae fratfer fears freg frat fax ate 1941-42 Fae fratfer fears freg frat fax 1941-42 Fae fratfer fears freg frat fax Fae fratfer fears freg frat fax fratfer fears freg frat fax fears freg frat fax freg frat fax frat fax faxsaHa tel ite afract A fratfedt, wae sare It HaHa F sayearat F ala FT Ta-saagIe FH ATAIT TT TH AUT fax ag afafretfea fran fr, Frazer ah 1940-41 ate 1941-42 Fae fratfer fears freg frat fax 1940-41 ate 1941-42 Fae fratfer fears freg frat fax ate 1941-42 Fae fratfer fears freg frat fax 1941-42 Fae fratfer fears freg frat fax Fae fratfer fears freg frat fax fratfer fears freg frat fax fears freg frat fax freg frat fax frat fax fax Ba Ta-e7agt & feat area wane aryq frond ae & fe fraifed a arma way att fetady A sarge Hay vet at att ag fe vag TAITftleafrera & alum ara faa afeada ae) & at fa fafteral ag & 1939-40°& ot afre oa 1941-42 asta ap SU Bfars aUTfate & eae F faa ag afraww e areata Tega fadat # sea satay& ame afraen. grr creat fav TT Ae F KITT HT ara gar fear war | Woy; | 28 Gr, 1940 att 9 aatat, 1940 ¥ Ste fraffedt & saa Hae faaaaa FF 28,47,380 way F 60,109 ala atar atari agar adder FF 28,47,380 way F 60,109 ala atar atari agar adder 28,47,380 way F 60,109 ala atar atari agar adder way F 60,109 ala atar atari agar adder F 60,109 ala atar atari agar adder 60,109 ala atar atari agar adder ala atar atari agar adder atar atari agar adder atari agar adder agar adder adder aqatar wraT4 ast ae gear Ht, GY gaat acqar ar aA 8, TAH FATT FaTearat H Var wei1 9 Haar, 1944 ate 20 WAC, 1944 H Hy say saa Falearm AAT aig 55,494 ater 36,80,174 eat Has fear ate va faa a13,43,469 qa afar oer ex at gam adhe at faya-azg d1 ala at aeHAT 19 maga, 1945 st ae at ag ate za fase B gh 33,481 era afearaet Ey at gat adie at faaa-aeg sr va wT &| aaa FF 28,47,380 way F 60,109 ala atar atari agar adder FF 28,47,380 way F 60,109 ala atar atari agar adder 28,47,380 way F 60,109 ala atar atari agar adder way F 60,109 ala atar atari agar adder F 60,109 ala atar atari agar adder 60,109 ala atar atari agar adder ala atar atari agar adder atar atari agar adder atari agar adder agar adder adder aq The sale proceeds o.f gold sold as aforesaid were utilised by the assessee in purchasing 7025 shares of Karanpura Develop-c ment Co. Ltd. for Rs. 2,37,267/. during the period from Decem-ber 8, 1944 to April 20, 1945 and shares of Bokaro Ramgur Co. for Rs. 39,81,663/- purchased in 1945-46. Part of the sale pro-ceeds were also utilised in purchasing the said Victory Bonds. Between November 8, 1945 and February 21, 1946, he sold 6950• of the Karanpura shares realising a net surplus of ~. 88,522/-, which t