COMMISSIONER OF WEALTH TAX Vs. SRIPAT SINGHANIA

JUDGEMENT

(1.) THE Income-tax Appellate Tribunal, Allahabad Bench, Allahabad, has referred the following question for the opinion of this court.

(2.) THE short facts giving rise to this reference are :

(3.) IT appears that the learned counsel for the assessee, before the Tribunal, had contended that Rule 1D was ultra vires the provisions of the Wealth-tax Act. The argument of the learned counsel for the revenue, in reply to the above contention, has been summarised by the Tribunal as follows :