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Issues: Whether a sole male member who had received property on partition and was unmarried during the relevant assessment year could be assessed in the status of a Hindu undivided family instead of as an individual.
Analysis: The expression "Hindu undivided family" in the Income-tax Act is understood in the sense of a Hindu joint family under personal law. A joint family may exist even with a single male member in the presence of wife, widows, or daughters entitled to maintenance, but the materials relied upon did not support the proposition that a lone male member without wife or children constitutes a Hindu undivided family. A person taking property on partition may have the potential to become the head of a joint family, but until he has a family unit capable of constituting a Hindu joint family, the property does not make him assessable as a Hindu undivided family.
Conclusion: The assessee was rightly assessed as an individual and not as a Hindu undivided family for the assessment year 1964-65.
Final Conclusion: The reference was answered against the assessee, affirming that a single unmarried coparcener without a family unit cannot be treated as a Hindu undivided family for tax assessment purposes.
Ratio Decidendi: For income-tax purposes, a Hindu undivided family requires the existence of a Hindu joint family unit and cannot be constituted by a solitary unmarried male member standing alone after partition.
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