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Issues:
1. Commissioner of Income-tax's authority to cancel registration under section 33B. 2. Determination of whether a partnership firm existed for section 26A purposes. 3. Specification of individual shares in the partnership deed. 4. Validity of the Commissioner's order canceling registration and tax determination. Analysis: The case involved an appeal by the Commissioner of Income-tax against a judgment canceling the registration of a partnership firm for three assessment years. The partnership deed provided for automatic succession of deceased partners' sons and grandsons as partners, which was a key aspect of the case. The High Court considered four questions, including the Commissioner's authority under section 33B, the firm's existence for section 26A, individual share specification, and the validity of the registration cancellation. The first question was not pressed and decided against the assessee, while the second was also ruled against the assessee on merits. The third question was deemed academic due to the decisions on the first two. The fourth question, which was the focus of the appeal, led to a difference of opinion among the judges. The majority judgment, based on precedent, favored the assessee, leading to the appeal by the Commissioner. The judgment cited a previous case, Commissioner of Income-tax v. Amritlal Bhogilal & Co., where the decision was reversed on appeal. Ultimately, the Supreme Court allowed the appeal, setting aside the High Court's judgment. The decision highlighted the importance of legal precedents and their impact on the outcome of tax-related cases. The judgment emphasized the need for consistency in interpreting tax laws and regulations to ensure fair and just outcomes for all parties involved.
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