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Issues: Whether, for assessment of a partner's share income from a firm, the "previous year" must be the previous year followed by the firm under section 3(1)(f) of the Income-tax Act, 1961, and not the assessee-partner's own accounting year.
Analysis: Section 3(1)(f) specifically governs only the share income of a partner in a firm that has been assessed as such. The provision is unambiguous and requires that the share income of the partner be computed for the same period that is the previous year for assessment of the firm's income. The partner's own previous year may govern other income, but it does not control the assessment of share income from the firm. The view that the date of closure of the assessee's accounts determines the relevant previous year for such share income was rejected.
Conclusion: The relevant previous year for the partner's share income is the previous year followed by the firm. The question was answered in favour of the Revenue and against the assessee.
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