Hindu Undivided Family status requires plurality of persons; a single unmarried individual was assessable only as an individual.

An unmarried Hindu male, with no other existing member in the alleged family, could not be assessed as a Hindu undivided family because an HUF requires plurality of persons and, for income-tax purposes, status must be determined on present facts. Section 2(31) treats an individual and an HUF as distinct taxable entities, and section 4 charges tax on every person accordingly. The Court rejected reliance on possible future adoption or other additions, as those possibilities did not establish that a single individual by himself constitutes an HUF. The assessee was therefore assessable only as an individual.

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Issues: Whether an unmarried male Hindu, on partition of a joint Hindu family, can be assessed in the status of a Hindu undivided family when no other person is a member of the alleged family.

Analysis: Section 4 of the Income-tax Act, 1961 charges tax on the total income of every person, and section 2(31) treats an individual and a Hindu undivided family as distinct entities. A family, in the ordinary and legal sense, connotes a group and plurality of persons is an essential attribute. Although under Hindu law a joint family may in some circumstances consist of a single male member with widows, the present case involved an unmarried assessee with no other existing member capable of constituting a family. The Court declined to speculate on possible future additions by adoption or otherwise and held that status for income-tax must be determined on present facts. The authorities relied upon for adoption and relation back did not assist the assessee because they did not establish that a single individual by himself constitutes a Hindu undivided family.

Conclusion: The assessee could not be assessed as a Hindu undivided family and was rightly assessed as an individual.

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