Book entries alone do not transfer immovable property for tax purposes; income remained taxable in the firm's hands.

Income from immovable property was treated as continuing to belong to the firm where the alleged transfer to partners was supported only by book entries and not by a registered deed. On that basis, the property was not regarded as validly transferred for tax purposes, so the rental or other income remained assessable in the hands of the firm rather than the individual partners. The deletion of the addition in the partners' assessments was therefore not sustained, and the issue was decided in favour of the assessee against the Revenue.

---

---

Issues: Whether the income from immovable property remained assessable in the hands of the firm where the alleged transfer to partners was sought to be effected only by book entries without a registered deed, and whether deletion of the addition in the partners' assessments was justified.

Analysis: The properties could not be treated as having been transferred from the firm to the partners merely by entries in the books. On that footing, the properties continued to belong to the firm for tax purposes, and the income arising from them was assessable in the hands of the firm rather than in the hands of the individual partners.

Conclusion: The question was answered in the affirmative, in favour of the assessee and against the Revenue.

---