(1.) THE source of this reference under section 66(1) of the Income-tax Act at the instance of the Commissioner of Income-tax is an assessment made by the Income-tax Officer with respect to the assessment years 1961-62 and 1962-63.
(2.) THE assessment was made in the following circumstances :
(3.) THE answer to the first question depends upon our interpretation of the provisions in the will. Two competing translations were produced before Income-tax authorities of the relevant provisions of the will, and we are of the opinion that there is no substantial difference between the one translation and the other.