(1.) THE only question of law referred to this Court by the Tribunal under S. 27(1) of the WT Act, 1957, is :
(2.) COUNSEL are agreed that, in view of this Court's decision in the case of CWT vs. Smt. Godavaribai R. Podar (1987) 63 CTR (Bom) 152 : (1988) 169 ITR 245, the word "jewellery" as used in the said cl. (viii) of S. 5(1) of the WT Act, 1957, cannot, for the period prior to 1st April, 1972, be held to include within its embrace ornaments made of gold or silver or platinum or other precious metal or alloy thereof which do not contain precious or semi precious stone or stones. Since the assessment years involved herein are assessment years prior to the asst. year 1972 73, the question of law is, accordingly, answered in the affirmative and in favour of the assessees.