Hindu Undivided Family Tax Status requires plurality of persons; notices against legal heirs of deceased karta were invalid.

A Hindu undivided family for tax purposes requires plurality of persons, and a single person, whether male or female, cannot constitute a family. Applying that principle, notices issued to the widow and divided son of a deceased karta, proposing assessment of agricultural income in their hands after the family had ceased to exist as a taxable unit, were unsustainable. The reasoning followed the Supreme Court and earlier decisions that such proceedings cannot be maintained against a sole surviving member or legal heirs in the manner proposed. The notices were therefore invalid and liable to be quashed.

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Issues: Whether notices issued to the widow and divided son of a deceased karta, proposing assessment of agricultural income for the relevant year in their hands, were valid when the family had ceased to exist as a taxable family unit.

Analysis: The deceased karta had, prior to his death, formed a smaller Hindu undivided family with his wife, and the notices proceeded on the footing that his widow and son could be assessed as legal heirs. The governing principle applied was that a family, for tax purposes, requires plurality of persons and a single person, male or female, cannot constitute a family. On that basis, the reasoning of the Supreme Court and the consistent view taken in earlier decisions was followed to hold that assessment proceedings could not be sustained against a sole surviving member or the legal heirs in the manner proposed.

Conclusion: The notices were invalid and liable to be quashed. The decision is in favour of the petitioners.

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