COMMISSIONER OF WEALTH TAX Vs. ABDULSAEED ABDULHAMID PATEL

JUDGEMENT

(1.) In these two references at the instance of the revenue, the Income-tax Appellate Tribunal, Ahmedabad Bench "A", under section 27 (1) of the Wealth-tax Act, 1957 ('the Act' for short), has referred the following common questions of law for our opinion for the assessment years 1981-82 and 1982-83:

(2.) Since common questions of law and facts are involved and the controversy raised in both these references is arising out of claim made by the respondents - assessees who are co-owners of the same property each having 1/3rd share in the property, for the sake of convenience, both these references are heard together and decided and disposed of by this common judgment.

(3.) In order to decide the controversy raised in these two references, it is relevant to refer to the facts stated in Reference No.57 of 1990.