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Issues:
1. Assessment status of legal heirs under Hindu Succession Act. 2. Determination of properties as joint family or individual. 3. Validity of assessment in the status of HUF. 4. Impression of assets with the character of joint family property. 5. Effect of widow's share on the assessment status. 6. Interpretation of partnership deed in relation to joint family status. 7. Impact of income-tax and wealth-tax returns on assessment status. 8. Devolution of estate on HUF after death of the deceased. 9. Application of legal precedent on devolution of assets. Analysis: The judgment involves determining the assessment status of legal heirs under the Hindu Succession Act. The WTO assessed the legal heirs as individuals, claiming they inherited properties separately. The AAC upheld this decision, leading to an appeal to the Tribunal. The Tribunal remitted the case to consider if the heirs lived as a joint family and if properties were thrown into the common hotchpot after the demise of the deceased. The AAC, upon reevaluation, concluded that the properties were joint family assets impressed with that character based on various circumstances. The main contention before the Tribunal was whether the assets left by the deceased were impressed with the character of joint family property. The Revenue argued that there was no evidence of a Hindu Undivided Family (HUF) and no declaration of properties being thrown into the family hotpot. The Tribunal analyzed the partnership deed of the firm involving the deceased and his sons, indicating a joint family setup. The Tribunal emphasized that the existence of a joint family, not just the property, is crucial for such impression. The Tribunal referred to legal precedents to support its decision. It cited a case where filing tax returns in the status of HUF was considered an unequivocal declaration of intent to impress properties with joint family character. In this case, after the demise of the deceased, income and wealth tax returns were filed as HUF, indicating the intention to treat the assets as joint family property. The widow's share was deemed to be gifted to the HUF, further supporting the joint family status. The assessee contended that the estate devolved on the HUF after the deceased's death. However, the Tribunal referenced a Madras High Court decision stating that the widow and sons became tenants-in-common, not HUF members, after the deceased's demise. Consequently, the appeal was dismissed, affirming the assessment in the status of HUF based on the evidence of joint family treatment of assets and tax filings.
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