Written settlement deed prevails over oral assertions, and rental income follows the individual ownership created by the document.

A clear and unambiguous settlement deed was construed according to its own terms, which vested the undivided half share absolutely in the assessee in his individual capacity and gave him the right to possess and enjoy it in his own right. For construing a written disposition of property in revenue matters, the general principles underlying sections 91, 92 and 94 of the Indian Evidence Act apply, so oral assertions, subsequent conduct, or a later affidavit cannot contradict, vary, or add to the document. On that basis, the rental income from the settled share was taxable in the assessee's individual hands and not as income of the Hindu undivided family.

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Issues: Whether the settlement deed vested the undivided half share in the assessee in his individual capacity or as property of the Hindu undivided family, and whether the rental income from that share was taxable in his individual hands.

Analysis: The settlement deed used clear and unambiguous language settling the undivided half share absolutely upon the assessee and conferring upon him the right to possess and enjoy the property in his own right. In revenue proceedings, though strict rules of evidence do not apply, the general principles underlying sections 91, 92 and 94 of the Indian Evidence Act, 1872 govern construction of a written disposition of property. Where the terms of the document are plain, oral assertions, subsequent conduct, or a later affidavit cannot be used to contradict, vary, or add to its contents. The legal character of the receipt of rent therefore had to be determined from the document itself.

Conclusion: The property was settled on the assessee absolutely in his individual capacity, and the rental income was taxable as his individual income, not as income of the Hindu undivided family.

Ratio Decidendi: A clear and unambiguous written disposition of property must be construed according to its terms, and extrinsic or subsequent evidence cannot be admitted to vary its legal effect in determining tax liability.

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