(1.) AT the instance of the Revenue, the Income Tax Appellate Tribunal, Chandigarh Bench, Chandigarh (for short 'the Tribunal') has referred the following question of law arising out of its order dated 25.10.1982 for the opinion of this Court :-
(2.) THE facts, as stated by the Tribunal, may first be noticed :- Late Maharaja Yadvindra Singh of Patiala was 9th in succession to the Gaddi of the State of Patiala. The State of Patiala was one of the groups of States known as the 'Phulkian States', which were governed by certain rules and regulations for succession and maintenance. These were recorded in the Dastur-ul-Amal containing provisions regarding authority of the Ruler of the State, maintenance of Kanwars and others etc.
(3.) DURING the financial year 1971-72, late Maharaja Yadvindra Singh transferred agricultural lands of the value of Rs. 3,82,500/- as under :-