THE COMMISSIONER OF INCOME-TAX,MADHYA PRADESH AND BHOPAL vs SODRA DEVI(with connected appeal)

The Supreme Court interpreted Section 16(3) of the Indian Income-tax Act, 1922, as amended by the Indian Income-tax (Amendment) Act, 1937, determining that the term 'individual' refers exclusively to males and does not encompass females. The Court held that income from a partnership admitted to minor sons cannot be included in the total income of their mother, a member of the partnership. The judgment disapproved prior cases, Shrimati Chanda Devi v. The Commissioner of Income-tax and Musta Quima Begum, In re, which suggested otherwise.