COMMISSIONER OF WEALTH TAX Vs. RAJKUMARI BANGUR

JUDGEMENT

(1.) THESE are three applications under Section 27(3) of the Wealth-tax Act, 1957, for directing the Income-tax Appellate Tribunal, Jaipur Bench, Jaipur, to state a case and refer the question of law arising out of the Tribunal's order dated June 24, 1977, passed in Wealth-tax Appeals Nos. 139, 140 and 141 JP 1976-77 for the assessment years 1967-68, 1968-69 and 1969-70.

(2.) THE reference applications have arisen out of the following facts :

(3.) IT was observed that the question of retrospectivity of the amendment was serious and highly debatable and could not be resolved without making a serious and studied attempt of the different amendments sought to be inserted in Section 5(1)(viii) of the Wealth-tax Act. The grant of exemption to the assessee could not, therefore, be treated as an error apparent from the record.