DARSH KUMAR GOEL, J. - (1.) THIS appeal has been preferred by the Revenue under s. 27A of the WT Act against the order of the Tribunal, Chandigarh following substantial question of law : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in allowing exemption under s. 5(1)(iii) of the WT Act to the assessee in respect of 'Mubarak Manzil' palace and surrounding lands admeasuring 75 kanals 10 -2/3 Marlas while she was not a ruler/ex -ruler in terms of Central Government notification entitling her to the exemption -
(2.) THE assessee is an individual and is widow of late Nawab of Malerkotla. During assessment under the provisions of WT Act, the AO noticed that value of the house known as "Mubarak Manzil" and land appurtenant to it were not shown by the assessee in her WT return. The stand of the assessee was that the property was official residence of erstwhile ruler of Malerkotla and thus, was exempt under s. 5(iii) of the Act r/w para 13 of the Merged States (Taxation Concession) Order, 1949.
(3.) THE AO rejected the claim of the assessee. The CWT(A) upheld the claim of the assessee and the Tribunal affirmed the same. We have heard learned counsel for the parties and perused the record.;