Income-Tax Officer vs Bishamber Lal on 23 March, 1982
[In this case, as no other element operated, it was held that the wife's share of profits arose wholly and exclusively from the sum which the assessee had given to his wife and her share of the profits could be included in the assessee's income.]" (p. 29)
Another case on which the learned departmental representative placed his reliance was that of U.S. Patel (supra) which also cannot be of any assistance to the contention of the revenue because in that case there were cross-gifts of the shares held by the assessee, U.S. Patel and it was on that basis that their Lordships of the Bombay High Court came to the following finding :