Law:

Section:

section 27 of the Wealth-tax Act, 1957 - Reference - Question of law - Whether question as to whether value of life interest and interest as reversioner in trust property was includible in total wealth of assessee in his individual capacity was a referable question of law - Held, yes Facts The assessee an individual was a beneficiary in two trusts holding life interest and also the right of a reversioner in the corpus of the trust property. The WTO included the value of life interest as well reversion to corpus in the trust property in the net wealth of the assessee. On appeal, the AAC held that the value of life interest and reversion were not includible in the net wealth of the assessee in his individual status. On appeal to the Tribunal, the order of AAC was upheld in view of the decision in the case of CWT v. Jambukumarsingh Kasliwal [Misc. Civil Case No. 347 of 1976]. The revenue's application for reference was also rejected. On application under section 27(3): Held The decision in the case of Jambukumarsingh Kasliwal (supra) was reversed by the Supreme Court in CIT v. Maharaja Bahadur Singh[1986] 162 ITR 343. In these circumstances a question of law did arise as to whether the value of the life interest and interest as reversioner was not includible in the total wealth of the assessee in his individual capacity. Cases referred to CWT v. Jambukumarsingh Kasliwal [Misc. Civil Case No. 347 of 1976] and CIT v. Maharaja Bahadur Singh [1986] 162 ITR 343(SC). R.C. Mukati for the Applicant. Kochatta for the Respondent. JUDGMENT Sohani, J. - The order in this case shall also govern the disposal of Mis-cellaneous Civil Case Nos. 213 to 215, 219, 220, 224 to 226, 229 to 242, 244 to 248, all of 1984. 2. These are applications under section 27(3) of the Wealth-tax Act, 1957 ('the Act'). 3. The material facts giving rise to these applications, briefly, are as follows: The assessee-respondent is a beneficiary in two trusts known as Sir Hukumchand Trust and Lady Kanchantai Trust. The assessee holds life interest in the two trusts and has also the right of a reversioner in the corpus of the trust property. While framing assessment of…

Deprecated: trim(): Passing null to parameter #1 ($string) of type string is deprecated in /home/digixyei/sldsystempk.com/view/master-layout/view_case.php on line 492