Partnership registration turns on ascertainable partner shares from related deeds, not a rigid single-document formula.

Registration under section 26A of the Income-tax Act, 1922 was considered in light of whether partners' individual shares had to appear in the principal partnership deed itself. The legal position stated is that the instrument must specify the shares with sufficient certainty, but those shares may be ascertained from the partnership documents read as a whole, including a related deed produced with the application. On that approach, the absence of separate fractional shares in the main deed was not fatal. The refusal of registration on a purely technical reading was therefore unsustainable, and the broader, contextual interpretation of the partnership documents was accepted.

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Issues: Whether the assessee-firm was entitled to registration under section 26A of the Income-tax Act, 1922, when the individual shares of some partners were not expressly set out in the principal deed but could be ascertained from another partnership deed produced with the application.

Analysis: Registration under section 26A and the Rules requires an instrument of partnership specifying the individual shares of the partners, and the application must be supported by the prescribed particulars. The Court held that the word "specified" does not necessarily mean that the fractional shares must be set out in one document on its face alone. Reading the partnership deed as a whole, and together with the related deed of the constituent firm produced before the Income-tax Officer, the individual shares were capable of being ascertained with certainty. The Court followed the later Supreme Court decisions which accepted that shares may be gathered from the partnership documents read reasonably and in context, and rejected the earlier restrictive view that excluded reference to other genuine documents.

Conclusion: The assessee-firm was entitled to registration under section 26A, and the refusal on the ground that the individual shares were not separately stated in the main deed was not sustainable.

Ratio Decidendi: Where the relevant partnership documents, read together and construed reasonably, clearly disclose the individual shares of the partners, section 26A is satisfied even if the shares are not expressed in one single deed, and a hyper-technical insistence on a solitary document is unwarranted.

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