TMI Blog1994 (8) TMI 4X X X X Extracts X X X X X X X X Extracts X X X X ..... ect of the assessment year 1972-73, at the instance of the assessee. The question referred reads as follows : " Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the remuneration received by Shri Balak Ram, karta of the assessee-Hindu undivided family was assessable in the assessee's hands ? " The Appellate Tribunal in its order states that it w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hemselves into a limited company. Thus the respective shares of all concerned persons certainly belonged to the erstwhile larger Hindu undivided family. It is in these circumstances and having regard to the fact that the articles of association of the company specifically provided for Balak Ram to be appointed as a director for life, the Appellate Tribunal ultimately concluded that the remuneratio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and that the remunerations paid to him were the income of the assessee-Hindu undivided family. Even if there was some element of personal service that would not change the character of the income." We do not find any error in the approach of the Appellate Tribunal. The finding is fully justified in view of the decision of the Supreme Court in P. N. Krishna Iyer v. CIT [1969] 73 ITR 539. The rel ..... X X X X Extracts X X X X X X X X Extracts X X X X
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