Partnership registration under section 26A requires one operative deed for the whole accounting year, not piecemeal registration.

Registration under section 26A required a single operative partnership instrument governing the relevant accounting year and specifying the partners' shares. Read with the later deed, the earlier partnership deed was treated as having been dissolved, with the business thereafter carried on by the continuing partners alone. On that construction, the earlier firm ceased as a taxable unit and the statute did not permit splitting the same accounting year into registered and unregistered parts. The provision demanded strict compliance and did not allow piecemeal registration for fragments of one accounting period.

---

---

Issues: Whether registration under section 26A could be granted for only part of the accounting year on the basis of the partnership deed dated 18 April 1957, and whether the subsequent deed dated 31 January 1958 showed a mere reconstitution or a dissolution of the firm.

Analysis: Registration under section 26A is registration of the instrument of partnership for the relevant accounting year, and the instrument must exist as a complete and operative document for that year and specify the individual shares of the partners. Reading the two deeds as a whole, the Court found that the language of the later deed repeatedly and expressly declared dissolution of the earlier firm, with the business thereafter to be carried on by the continuing partners for their benefit alone. On that construction, the earlier firm ceased to exist as a taxable unit, and the statute did not permit splitting the accounting period into a registered part and an unregistered part. The Court further held that section 26A required strict conformity with the statutory conditions and did not support piecemeal registration for different fragments of the same accounting year.

Conclusion: Registration under section 26A could not be granted for only part of the accounting year, and the Tribunal was wrong in allowing registration for the period from 1 February 1957 to 30 September 1957.

Ratio Decidendi: Section 26A permits registration only where a single operative instrument of partnership, specifying the partners' shares, governs the firm for the relevant accounting year as a whole; the provision does not permit piecemeal registration for different parts of the same year where the earlier firm has been dissolved.

---