COMMISSIONER OF WEALTH TAX Vs. ZAINAB NOORUL SAYEED

JUDGEMENT

(1.) THESE R.Cs. may be disposed of by a common order, since the question referred for the opinion of this Court is common in all these cases.

(2.) THE Tribunal, Hyderabad Bench, referred the following question, said to be a question of law, for the opinion of this Court : "Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in allowing the exemption under S. 5(1)(xii) of the WT Act in respect of seven items of jewellery claimed to represent art treasures ?" In this batch of cases, we are concerned only with the said question.

(3.) IN this batch of cases, Sri S.R. Ashok, learned senior standing counsel appearing for and on behalf of the Revenue, contended that the view taken by the Tribunal is totally erroneous and contrary to the scheme of the provisions of the WT Act. It is submitted by the learned senior standing counsel that for the purposes of the WT Act, even those seven items continued to be jewellery and, therefore, they are not exempted and are liable to be included in the net wealth of the assessees.