(1.) AT the instance of the Department, the Income-tax Appellate Tribunal, has stated a case and referred the following common question of law under section 27(1) of the Wealth-tax Act, 1957, for our opinion :
(2.) THE assessee is an individual. He transferred certain amounts to M. C. Shyamala Marriage Benefit Trust and M. C. Sowmyaram Marriage Benefit Trust. THE Wealth-tax Officer in the assessment proceedings for the assessment years 1980-81 and 1981-82 held that the trusts were revocable trusts and, therefore, the amount transferred should be included under section 4(1)(a)(iv) of the Wealth-tax Act and made additions of Rs. 1,43,960 and Rs. 1,69,873 respectively for the assessment years 1980-81 and 1981-82.