(1.) THE Tribunal, Allahabad, has referred the two questions of law under s. 27(1) of the WT Act, 1957, hereinafter referred to as 'the Act', for opinion to this Court :
(2.) THE present reference relates to the asst. yrs. 1973 -74 to 1975 -76.
(3.) BRIEFLY stated, the facts giving rise to the present reference are as follows : The assessees who are Gopal Sutwala (Individual), Gopal Sutwala (Karta) of Hira Lal Sutwala (HUF) and Smt. Parti Devi (HUF) are co -owners in the following five properties :