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Issues:
- Determination of income status after marriage in Hindu Undivided Family (HUF) Analysis: The case involved a reference under s. 256(1) of the Income Tax Act, 1961, where the Tribunal questioned the correctness of assessing the income of an individual as part of an HUF after marriage. The assessee, who received assets on partition of an HUF when unmarried, later claimed his status changed to HUF after marriage, leading to a dispute on the assessment of income. The High Court analyzed the legal principles established by previous judgments. It referred to the Supreme Court's decision in C. Krishna Prasad v. CIT, emphasizing that for an HUF to be a taxable entity, it must consist of two or more members. The Court also cited the case of Surjit Lal Chhabda v. CIT, where it was held that income from self-acquired property thrown into the family hotchpot remained the individual's income until the birth of a son. The Court applied these principles to the current case. The Court concluded that the marriage of the assessee did not alter his status or the nature of the property received in partition as a single member. Without a son, the assessee retained absolute ownership over the property, making his income taxable as an individual. The Court disagreed with a previous Allahabad High Court decision that recognized an HUF after an individual's marriage without considering the Supreme Court's ruling in Surjit Lal Chhabda's case. Ultimately, the High Court answered the question in the negative, favoring the Department's position. The assessee was deemed liable to be assessed as an individual, maintaining the status as before marriage. Each party was directed to bear their own costs in the reference.
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