(1.) IN all these matters common questions of law have been referred to this court for its opinion pursuant to a direction of this court under Section 27(3) of the Wealth-tax Act, 1957. The assessee in all the cases is the same, and the references relate to different assessment years, namely, assessment years 1966-67 to 1971-72. The questions of law referred to this court for its opinion are the following :
(2.) WHETHER, on the facts and in the circumstances of the case, the order of the Income-tax Appellate Tribunal is perverse and not based on law ?"
(3.) BY the same Finance (No. 2) Act, 1971, two provisos and two Explanations were also added which were made effective from April 1, 1972, i.e., prospectively. Explanation 1 deserves to be noticed. It provides :