- (1.) These appeals by certificate under sec. 29 of the Wealth Tax Act, 1957 (to be hereinafter referred to as the Act) arise from a reference under sec. 27(1) of the Act to the High Court of Gujarat. Therein four questions were referred to the High Court for its opinion. These four questions really gave rise to two question of law viz. (1) whether under the three trust deeds referred to therein the assesSec got annuities falling within the scope of sec. 2(e)(iv) and (2) whether the value of the jewels owned by the assesSec was exempt under sec. 5(1)(viii) in computing the net wealth of the assessec
(2.) The assesSec is an individual and the assessment years with which we are concerned in these appeals are 1957-58 and 1958-59, the corresponding valuation dates being December 31, 1956 and December 31, 1957.
(3.) By a deed of settlement dated September 7, 1945 the father of the assesSec settled certain shares of the Indian Companies of the estimated value of Rs. 5, 50, 325 upon trust for the benefit of his two sons and his daughter, the assesSec. By another deed of settlement dated October 12, 1945 he settled certain other shares upon trust for the benefit of the assesSec and her two brothers. All the terms of the two trust deeds relevant for our present purpose are identical. By a deed of settlement dated September 30, 1945, the monther-in-law of the assesSec settled upon trust a sum of Rs. 3, 88, 931 and shares of some Indian Companies of the aggregate market value of Rs. 11, 81, 670. The assesSec is one of the beneficiaries named in that deed. The assesSec also possessed jewellery of the value of Rs. 80, 000.;