Ratification by an adopted son can limit joint family income to the share validly dealt with in the family arrangement.

An adopted son's later, voluntary ratification of an arrangement dealing with family property was effective after he attained majority, and the consent of the natural father did not by itself curtail the adopted son's rights. The later document was treated as a valid act of ratification under Hindu law and tax law, so the property was not wholly available as joint family property to the extent covered by that arrangement. The Hindu undivided family was therefore assessable only on income from the one-fourth share dealt with by the arrangement, not on income from the entire one-half share.

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Issues: Whether, on the documents executed in connection with the adoption and subsequent ratification, the Hindu undivided family was assessable on the income from the entire one-half share of Kastoorchand Mills Estate or only on the income attributable to one-fourth share therein.

Analysis: The arrangement first recorded after the adoption could not operate to curtail the adopted son's rights merely by reason of the natural father's consent. However, the adopted son, after attaining majority, was competent to adopt the arrangement for himself and to treat the property in the manner reflected in the later document. The later document was found to be a voluntary act of ratification, and there was no legal bar in Hindu law or in the tax law against giving effect to it. On that basis, the property ceased to be wholly available as joint family property to the extent of the one-fourth share dealt with by the arrangement.

Conclusion: The family was taxable only on the income from the one-fourth share of the property, and not on the income from the entire one-half share.

Ratio Decidendi: A competent adopted son, after attaining majority, may validly ratify and give effect to an arrangement governing family property, and such bona fide arrangement can determine the extent to which income remains assessable as joint family income.

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