Section 171 — Assessment After Partition of a Hindu Undivided Family
Case Laws & Commentary · Income-tax Act, 1961 (as amended by the Finance Act, 2026) · bharattax.co Treatise
Provision: Live. Part G of Chapter XV (Partition). Successor to section 25A of the 1922 Act; sub-section (9) (non-recognition of partial partitions after 31-12-1978) inserted by the Finance (No. 2) Act, 1980.
Subject: An HUF hitherto assessed as undivided is deemed to continue as an HUF except where a finding of partition is recorded under the section; a claim of partition is to be inquired into and a finding recorded by the Assessing Officer; on total partition the members are jointly and severally liable for the pre-partition tax (each member's several liability being limited to his share of the joint family property); and partial partitions effected after 31 December 1978 are not recognised (sub-section (9)).
Finance Act, 2026: No change. Chapter XV is untouched by the Finance Act, 2026; the section stands as amended up to the Finance Act, 2025.
A. SECTION COMMENTARY
1. The deeming and the special meaning of 'partition'
Section 171 is built on a deeming. An HUF that has hitherto been assessed as undivided is deemed, for the purposes of the Act, to continue to be an HUF — and therefore to remain assessable as such — except where, and to the extent that, a finding of partition has been recorded under the section. Crucially, 'partition' bears a special, narrower meaning than under general Hindu law: by the Explanation, a partition (where the property admits of physical division) requires division by metes and bounds; a mere notional or partial division, or a division of income while the income-producing asset remains intact, is not a 'partition' for the section (Kalloomal Tapeswari Prasad; Charandas Haridas). Until the Assessing Officer records a finding of partition, the family continues to be assessed as an HUF on the whole income.
2. The inquiry and finding
Where a claim of total partition is made, the Assessing Officer must inquire into it after notice to the members and record a finding whether, and on what date, a total partition took place. The deeming in sub-section (1) is displaced only by such a finding; this is what gives section 171 its gatekeeping character — recognition for tax purposes turns on the statutory finding, not merely on the fact of severance under personal law (Kalwa Devadattam).
3. Partial partition and sub-section (9)
Before 1980, a partial partition (of some members, or of some only of the family's properties) could be recognised, and a father could effect a bona fide partial partition between himself and his minor sons (Apoorva Shantilal Shah). Sub-section (9), inserted by the Finance (No. 2) Act 1980 with effect from partitions after 31 December 1978, reversed this: partial partitions effected after that date are not recognised, the family continuing to be assessed as if no such partial partition had taken place, with the members jointly and severally liable. The Madras High Court struck sub-section (9) down as violative of Article 14 (M.V. Valliappan), but the Supreme Court reversed that decision and upheld the provision as within Parliament's competence (Union of India v. M.V. Valliappan); the non-recognition rule holds even where the partial partition is effected by a court decree (Sarada Thampatty).
4. Post-partition liability of members; prospectivity
On a recognised total partition, sub-sections (6) and (7) fix the members' liability for the pre-partition tax of the family: every member is jointly and severally liable, but the several liability of each is limited to the portion of the joint-family property allotted to him on partition (A. Thimmayya distinguishes the joint liability, which is not so limited, from the several liability, which is). These member-liability provisions are substantive and operate prospectively; the Constitution Bench in Govinddas held they cannot be applied to recover, from members, tax on assessments completed under the 1922 Act.
B. STATUTORY POSITION (verbatim text)
The text of the section, as it stands in the Act (FA-2025 base), is set out below.
171. (1) A Hindu family hitherto assessed as undivided shall be deemed for the purposes of this Act to continue to be a Hindu undivided family, except where and in so far as a finding of partition has been given under this section in respect of the Hindu undivided family.
(2) Where, at the time of making an assessment under section 143 or section 144, it is claimed by or on behalf of any member of a Hindu family assessed as undivided that a partition, whether total or partial, has taken place among the members of such family, the Assessing Officer shall make an inquiry thereinto after giving notice of the inquiry to all the members of the family.
(3) On the completion of the inquiry, the Assessing Officer shall record a finding as to whether there has been a total or partial partition of the joint family property, and, if there has been such a partition, the date on which it has taken place.
(4) Where a finding of total or partial partition has been recorded by the Assessing Officer under this section, and the partition took place during the previous year,—
(a) the total income of the joint family in respect of the period up to the date of partition shall be assessed as if no partition had taken place; and
(b) each member or group of members shall, in addition to any tax for which he or it may be separately liable and notwithstanding anything contained in clause (2) of section 10, be jointly and severally liable for the tax on the income so assessed.
(5) Where a finding of total or partial partition has been recorded by the Assessing Officer under this section, and the partition took place after the expiry of the previous year, the total income of the previous year of the joint family shall be assessed as if no partition had taken place; and the provisions of clause (b) of sub-section (4) shall, so far as may be, apply to the case.
(6) Notwithstanding anything contained in this section, if the Assessing Officer finds after completion of the assessment of a Hindu undivided family that the family has already effected a partition, whether total or partial, the Assessing Officer shall proceed to recover the tax from every person who was a member of the family before the partition, and every such person shall be jointly and severally liable for the tax on the income so assessed.
(7) For the purposes of this section, the several liability of any member or group of members thereunder shall be computed according to the portion of the joint family property allotted to him or it at the partition, whether total or partial.
(8) The provisions of this section shall, so far as may be, apply in relation to the levy and collection of any penalty, interest, fine or other sum in respect of any period up to the date of the partition, whether total or partial, of a Hindu undivided family as they apply in relation to the levy and collection of tax in respect of any such period.
(9) Notwithstanding anything contained in the foregoing provisions of this section, where a partial partition has taken place after the 31st day of December, 1978, among the members of a Hindu undivided family hitherto assessed as undivided,—
(a) no claim that such partial partition has taken place shall be inquired into under sub-section (2) and no finding shall be recorded under sub-section (3) that such partial partition had taken place and any finding recorded under sub-section (3) to that effect whether before or after the 18th day of June, 1980, being the date of introduction of the Finance (No. 2) Bill, 1980, shall be null and void;
(b) such family shall continue to be liable to be assessed under this Act as if no such partial partition had taken place;
(c) each member or group of members of such family immediately before such partial partition and the family shall be jointly and severally liable for any tax, penalty, interest, fine or other sum payable under this Act by the family in respect of any period, whether before or after such partial partition;
(d) the several liability of any member or group of members aforesaid shall be computed according to the portion of the joint family property allotted to him or it at such partial partition, and the provisions of this Act shall apply accordingly.
Explanation.—In this section,—
(a) "partition" means—
(i) where the property admits of a physical division, a physical division of the property, but a physical division of the income without a physical division of the property producing the income shall not be deemed to be a partition; or
(ii) where the property does not admit of a physical division, then such division as the property admits of, but a mere severance of status shall not be deemed to be a partition;
(b) "partial partition" means a partition which is partial as regards the persons constituting the Hindu undivided family, or the properties belonging to the Hindu undivided family, or both.
C. AUTHORITIES
Section 171 is heavily litigated. The authorities on the special meaning of partition, partial partition and sub-section (9), and member liability, are grouped below. All citations are web-verified; the Madras-HC striking down of sub-section (9) and its reversal by the Supreme Court are both included.
Cluster A — Special meaning of 'partition'; HUF continues until a section 171 finding
Kalloomal Tapeswari Prasad (HUF) v. CIT, Kanpur
Citation: (1982) 133 ITR 690 (SC)
Facts: A claim of partition where immovable property was not divided by metes and bounds; interaction of Hindu-law partition with the Explanation to section 171.
Held: The Explanation gives 'partition' a special meaning narrower than Hindu law — physical division by metes and bounds is required where the property admits of it; property subjected only to a partial/notional partition continues to be treated as belonging to the family, and its income is assessed as HUF income, until the officer records a finding of partition under section 171.
Relevance: The leading Supreme Court authority on the special meaning of 'partition' and the 'HUF continues till a section 171 order' principle.
Charandas Haridas v. CIT, Bombay North
Citation: (1960) 39 ITR 202 (SC)
Facts: A karta orally divided managing-agency commission income among family members, the managing-agency agreements themselves remaining unchanged.
Held: What was divided was the income, not the asset producing it; a division of income alone, leaving the income-producing asset intact, is not an effective partition recognisable for assessment.
Relevance: Classic authority distinguishing genuine partition of the corpus from mere division/diversion of income.
Kalwa Devadattam & Ors. v. Union of India
Citation: (1963) 49 ITR 165 (SC)
Facts: Tax assessed on an HUF; whether, after severance of joint status, the pre-existing HUF tax could be recovered and the effect of section 25A on continuing liability.
Held: Until an order recording partition is made, the family is assessed and liable as an HUF; severance of status does not by itself defeat the HUF's tax liability — the statutory machinery (now section 171) governs.
Relevance: Early authority on continuing HUF liability pending a partition order — the lineage of section 171's 'deemed HUF until order' rule.
Cluster B — Partial partition and sub-section (9)
Apoorva Shantilal Shah (HUF) v. CIT, Gujarat I
Citation: (1983) 141 ITR 558 (SC)
Facts: A karta-father effected a partial partition of shares between himself and his minor sons in a Mitakshara family; the officer declined recognition.
Held: A father can, in exercise of his power, effect a bona fide partial partition between himself and his minor sons; if fair and not unequal, such a partial partition is valid and must be recognised under section 171 (for the period before sub-section (9) barred partial partitions).
Relevance: Leading authority upholding the validity and recognition of partial partition under section 171 before the 1980 amendment.
M.V. Valliappan & Ors. v. ITO
Citation: (1988) 170 ITR 238 (Mad)
Facts: Writ challenge to the constitutional validity of section 171(9) (and the cognate section 20A of the Wealth-tax Act).
Held: Section 171(9) was struck down as violative of Article 14 and beyond legislative competence.
Relevance: The High-Court decision invalidating section 171(9) — important to the litigation history, but later reversed (see below).
Union of India v. M.V. Valliappan
Citation: (1999) 238 ITR 1027 (SC)
Facts: The Revenue's appeal against the Madras High Court striking down section 171(9).
Held: Section 171(9) (and section 20A of the Wealth-tax Act) is within Parliament's legislative competence and not unconstitutional; it is for the Legislature to decide whether to recognise partial partition for levy and collection of tax. The High Court judgment was set aside.
Relevance: The controlling authority restoring section 171(9); read with Sarada Thampatty.
ITO v. Smt. N.K. Sarada Thampatty
Citation: (1991) 187 ITR 696 (SC)
Facts: A claim of partial partition; whether a court decree could displace the statutory bar.
Held: After insertion of sub-section (9), partial partitions effected after 31-12-1978 are not to be recognised; the special meaning of 'partition' cannot be ignored even where the partition is by a court decree.
Relevance: Authoritative on the non-recognition of post-31-12-1978 partial partitions under section 171(9).
Cluster C — Post-partition liability of members; prospectivity
Facts: HUF assessments under the 1922 Act; the Revenue sought to recover the tax personally from members invoking section 171(6)/(7) of the 1961 Act.
Held: A statute is presumed prospective unless retrospectivity is express or by necessary implication; section 171(6)/(7), affecting substantive liability of members for pre-existing dues, cannot be applied retrospectively to assessments completed under the 1922 Act.
Relevance: Leading authority on the substantive, non-retrospective character of the member-liability provisions in section 171(6)/(7).
Addl. ITO v. A. Thimmayya
Citation: (1965) 55 ITR 666 (SC)
Facts: The nature and extent of an erstwhile member's liability for HUF tax after partition.
Held: The joint liability of a member is not limited to the assets received on partition, whereas the several liability (now section 171(7)) is limited to the share of joint-family property allotted to him; the conditions for recognising partition must co-exist.
Relevance: Distinguishes joint from several liability of members after partition — directly construes the liability scheme now in section 171(6)/(7).
Compiled for the bharattax.co Treatise on the Income-tax Act, 1961 (as amended by the Finance Act, 2026). Statutory text is reproduced from the Income-tax Act, 1961 (text as printed in the local Act, base text amended up to the Finance Act, 2025), with the publisher's footnote apparatus and amendment-marker brackets removed; three asterisks (***) denote words or a provision omitted by amendment and retained only to mark the omission. The Finance Act, 2026 amends no section of Chapter XV of the Income-tax Act, 1961 (its Part-A amendments touch ss.92CA, 139, 140B, 144B, 144C, 147A, 148, 150, 153, 153B, 220, 222, 234, 245, 245MA, 254 and 270A-276 only). Citations are stated as reported; orders of the Tribunal and High Courts are flagged as such. Where a section has not been judicially construed, that is stated candidly and the nearest governing authority is given. This material is for professional reference and is not legal advice.
CHAPTER XV — LIABILITY IN SPECIAL CASES
Section 171 — Assessment After Partition of a Hindu Undivided Family
Case Laws & Commentary · Income-tax Act, 1961 (as amended by the Finance Act, 2026) · bharattax.co Treatise
Provision: Live. Part G of Chapter XV (Partition). Successor to section 25A of the 1922 Act; sub-section (9) (non-recognition of partial partitions after 31-12-1978) inserted by the Finance (No. 2) Act, 1980.
Subject: An HUF hitherto assessed as undivided is deemed to continue as an HUF except where a finding of partition is recorded under the section; a claim of partition is to be inquired into and a finding recorded by the Assessing Officer; on total partition the members are jointly and severally liable for the pre-partition tax (each member's several liability being limited to his share of the joint family property); and partial partitions effected after 31 December 1978 are not recognised (sub-section (9)).
Finance Act, 2026: No change. Chapter XV is untouched by the Finance Act, 2026; the section stands as amended up to the Finance Act, 2025.
A. SECTION COMMENTARY
1. The deeming and the special meaning of 'partition'
Section 171 is built on a deeming. An HUF that has hitherto been assessed as undivided is deemed, for the purposes of the Act, to continue to be an HUF — and therefore to remain assessable as such — except where, and to the extent that, a finding of partition has been recorded under the section. Crucially, 'partition' bears a special, narrower meaning than under general Hindu law: by the Explanation, a partition (where the property admits of physical division) requires division by metes and bounds; a mere notional or partial division, or a division of income while the income-producing asset remains intact, is not a 'partition' for the section (Kalloomal Tapeswari Prasad; Charandas Haridas). Until the Assessing Officer records a finding of partition, the family continues to be assessed as an HUF on the whole income.
2. The inquiry and finding
Where a claim of total partition is made, the Assessing Officer must inquire into it after notice to the members and record a finding whether, and on what date, a total partition took place. The deeming in sub-section (1) is displaced only by such a finding; this is what gives section 171 its gatekeeping character — recognition for tax purposes turns on the statutory finding, not merely on the fact of severance under personal law (Kalwa Devadattam).
3. Partial partition and sub-section (9)
Before 1980, a partial partition (of some members, or of some only of the family's properties) could be recognised, and a father could effect a bona fide partial partition between himself and his minor sons (Apoorva Shantilal Shah). Sub-section (9), inserted by the Finance (No. 2) Act 1980 with effect from partitions after 31 December 1978, reversed this: partial partitions effected after that date are not recognised, the family continuing to be assessed as if no such partial partition had taken place, with the members jointly and severally liable. The Madras High Court struck sub-section (9) down as violative of Article 14 (M.V. Valliappan), but the Supreme Court reversed that decision and upheld the provision as within Parliament's competence (Union of India v. M.V. Valliappan); the non-recognition rule holds even where the partial partition is effected by a court decree (Sarada Thampatty).
4. Post-partition liability of members; prospectivity
On a recognised total partition, sub-sections (6) and (7) fix the members' liability for the pre-partition tax of the family: every member is jointly and severally liable, but the several liability of each is limited to the portion of the joint-family property allotted to him on partition (A. Thimmayya distinguishes the joint liability, which is not so limited, from the several liability, which is). These member-liability provisions are substantive and operate prospectively; the Constitution Bench in Govinddas held they cannot be applied to recover, from members, tax on assessments completed under the 1922 Act.
B. STATUTORY POSITION (verbatim text)
The text of the section, as it stands in the Act (FA-2025 base), is set out below.
171. (1) A Hindu family hitherto assessed as undivided shall be deemed for the purposes of this Act to continue to be a Hindu undivided family, except where and in so far as a finding of partition has been given under this section in respect of the Hindu undivided family.
(2) Where, at the time of making an assessment under section 143 or section 144, it is claimed by or on behalf of any member of a Hindu family assessed as undivided that a partition, whether total or partial, has taken place among the members of such family, the Assessing Officer shall make an inquiry thereinto after giving notice of the inquiry to all the members of the family.
(3) On the completion of the inquiry, the Assessing Officer shall record a finding as to whether there has been a total or partial partition of the joint family property, and, if there has been such a partition, the date on which it has taken place.
(4) Where a finding of total or partial partition has been recorded by the Assessing Officer under this section, and the partition took place during the previous year,—
(a) the total income of the joint family in respect of the period up to the date of partition shall be assessed as if no partition had taken place; and
(b) each member or group of members shall, in addition to any tax for which he or it may be separately liable and notwithstanding anything contained in clause (2) of section 10, be jointly and severally liable for the tax on the income so assessed.
(5) Where a finding of total or partial partition has been recorded by the Assessing Officer under this section, and the partition took place after the expiry of the previous year, the total income of the previous year of the joint family shall be assessed as if no partition had taken place; and the provisions of clause (b) of sub-section (4) shall, so far as may be, apply to the case.
(6) Notwithstanding anything contained in this section, if the Assessing Officer finds after completion of the assessment of a Hindu undivided family that the family has already effected a partition, whether total or partial, the Assessing Officer shall proceed to recover the tax from every person who was a member of the family before the partition, and every such person shall be jointly and severally liable for the tax on the income so assessed.
(7) For the purposes of this section, the several liability of any member or group of members thereunder shall be computed according to the portion of the joint family property allotted to him or it at the partition, whether total or partial.
(8) The provisions of this section shall, so far as may be, apply in relation to the levy and collection of any penalty, interest, fine or other sum in respect of any period up to the date of the partition, whether total or partial, of a Hindu undivided family as they apply in relation to the levy and collection of tax in respect of any such period.
(9) Notwithstanding anything contained in the foregoing provisions of this section, where a partial partition has taken place after the 31st day of December, 1978, among the members of a Hindu undivided family hitherto assessed as undivided,—
(a) no claim that such partial partition has taken place shall be inquired into under sub-section (2) and no finding shall be recorded under sub-section (3) that such partial partition had taken place and any finding recorded under sub-section (3) to that effect whether before or after the 18th day of June, 1980, being the date of introduction of the Finance (No. 2) Bill, 1980, shall be null and void;
(b) such family shall continue to be liable to be assessed under this Act as if no such partial partition had taken place;
(c) each member or group of members of such family immediately before such partial partition and the family shall be jointly and severally liable for any tax, penalty, interest, fine or other sum payable under this Act by the family in respect of any period, whether before or after such partial partition;
(d) the several liability of any member or group of members aforesaid shall be computed according to the portion of the joint family property allotted to him or it at such partial partition, and the provisions of this Act shall apply accordingly.
Explanation.—In this section,—
(a) "partition" means—
(i) where the property admits of a physical division, a physical division of the property, but a physical division of the income without a physical division of the property producing the income shall not be deemed to be a partition; or
(ii) where the property does not admit of a physical division, then such division as the property admits of, but a mere severance of status shall not be deemed to be a partition;
(b) "partial partition" means a partition which is partial as regards the persons constituting the Hindu undivided family, or the properties belonging to the Hindu undivided family, or both.
C. AUTHORITIES
Section 171 is heavily litigated. The authorities on the special meaning of partition, partial partition and sub-section (9), and member liability, are grouped below. All citations are web-verified; the Madras-HC striking down of sub-section (9) and its reversal by the Supreme Court are both included.
Cluster A — Special meaning of 'partition'; HUF continues until a section 171 finding
Kalloomal Tapeswari Prasad (HUF) v. CIT, Kanpur
Citation: (1982) 133 ITR 690 (SC)
Facts: A claim of partition where immovable property was not divided by metes and bounds; interaction of Hindu-law partition with the Explanation to section 171.
Held: The Explanation gives 'partition' a special meaning narrower than Hindu law — physical division by metes and bounds is required where the property admits of it; property subjected only to a partial/notional partition continues to be treated as belonging to the family, and its income is assessed as HUF income, until the officer records a finding of partition under section 171.
Relevance: The leading Supreme Court authority on the special meaning of 'partition' and the 'HUF continues till a section 171 order' principle.
Charandas Haridas v. CIT, Bombay North
Citation: (1960) 39 ITR 202 (SC)
Facts: A karta orally divided managing-agency commission income among family members, the managing-agency agreements themselves remaining unchanged.
Held: What was divided was the income, not the asset producing it; a division of income alone, leaving the income-producing asset intact, is not an effective partition recognisable for assessment.
Relevance: Classic authority distinguishing genuine partition of the corpus from mere division/diversion of income.
Kalwa Devadattam & Ors. v. Union of India
Citation: (1963) 49 ITR 165 (SC)
Facts: Tax assessed on an HUF; whether, after severance of joint status, the pre-existing HUF tax could be recovered and the effect of section 25A on continuing liability.
Held: Until an order recording partition is made, the family is assessed and liable as an HUF; severance of status does not by itself defeat the HUF's tax liability — the statutory machinery (now section 171) governs.
Relevance: Early authority on continuing HUF liability pending a partition order — the lineage of section 171's 'deemed HUF until order' rule.
Cluster B — Partial partition and sub-section (9)
Apoorva Shantilal Shah (HUF) v. CIT, Gujarat I
Citation: (1983) 141 ITR 558 (SC)
Facts: A karta-father effected a partial partition of shares between himself and his minor sons in a Mitakshara family; the officer declined recognition.
Held: A father can, in exercise of his power, effect a bona fide partial partition between himself and his minor sons; if fair and not unequal, such a partial partition is valid and must be recognised under section 171 (for the period before sub-section (9) barred partial partitions).
Relevance: Leading authority upholding the validity and recognition of partial partition under section 171 before the 1980 amendment.
M.V. Valliappan & Ors. v. ITO
Citation: (1988) 170 ITR 238 (Mad)
Facts: Writ challenge to the constitutional validity of section 171(9) (and the cognate section 20A of the Wealth-tax Act).
Held: Section 171(9) was struck down as violative of Article 14 and beyond legislative competence.
Relevance: The High-Court decision invalidating section 171(9) — important to the litigation history, but later reversed (see below).
Union of India v. M.V. Valliappan
Citation: (1999) 238 ITR 1027 (SC)
Facts: The Revenue's appeal against the Madras High Court striking down section 171(9).
Held: Section 171(9) (and section 20A of the Wealth-tax Act) is within Parliament's legislative competence and not unconstitutional; it is for the Legislature to decide whether to recognise partial partition for levy and collection of tax. The High Court judgment was set aside.
Relevance: The controlling authority restoring section 171(9); read with Sarada Thampatty.
ITO v. Smt. N.K. Sarada Thampatty
Citation: (1991) 187 ITR 696 (SC)
Facts: A claim of partial partition; whether a court decree could displace the statutory bar.
Held: After insertion of sub-section (9), partial partitions effected after 31-12-1978 are not to be recognised; the special meaning of 'partition' cannot be ignored even where the partition is by a court decree.
Relevance: Authoritative on the non-recognition of post-31-12-1978 partial partitions under section 171(9).
Cluster C — Post-partition liability of members; prospectivity
Govinddas & Ors. v. ITO
Citation: (1976) 103 ITR 123 (SC)(Constitution Bench)
Facts: HUF assessments under the 1922 Act; the Revenue sought to recover the tax personally from members invoking section 171(6)/(7) of the 1961 Act.
Held: A statute is presumed prospective unless retrospectivity is express or by necessary implication; section 171(6)/(7), affecting substantive liability of members for pre-existing dues, cannot be applied retrospectively to assessments completed under the 1922 Act.
Relevance: Leading authority on the substantive, non-retrospective character of the member-liability provisions in section 171(6)/(7).
Addl. ITO v. A. Thimmayya
Citation: (1965) 55 ITR 666 (SC)
Facts: The nature and extent of an erstwhile member's liability for HUF tax after partition.
Held: The joint liability of a member is not limited to the assets received on partition, whereas the several liability (now section 171(7)) is limited to the share of joint-family property allotted to him; the conditions for recognising partition must co-exist.
Relevance: Distinguishes joint from several liability of members after partition — directly construes the liability scheme now in section 171(6)/(7).
Compiled for the bharattax.co Treatise on the Income-tax Act, 1961 (as amended by the Finance Act, 2026). Statutory text is reproduced from the Income-tax Act, 1961 (text as printed in the local Act, base text amended up to the Finance Act, 2025), with the publisher's footnote apparatus and amendment-marker brackets removed; three asterisks (***) denote words or a provision omitted by amendment and retained only to mark the omission. The Finance Act, 2026 amends no section of Chapter XV of the Income-tax Act, 1961 (its Part-A amendments touch ss.92CA, 139, 140B, 144B, 144C, 147A, 148, 150, 153, 153B, 220, 222, 234, 245, 245MA, 254 and 270A-276 only). Citations are stated as reported; orders of the Tribunal and High Courts are flagged as such. Where a section has not been judicially construed, that is stated candidly and the nearest governing authority is given. This material is for professional reference and is not legal advice.