JUDGMENT

Syed Shah Mohammed Quadri, J.-These appeals arise out of two reference cases under Section 27(1) of the Wealth-tax Act, 1957 decided by the High Court of Andhra Pradesh, give rise to a common question of law. The appellants are the assessees. Civil Appeal No. 2328 of 1995 is against the order of the Division Bench of the High Court in R.C. No. 192 of 1980 dated March 24, 1987 (reported in 171 ITR 323] pertaining to the Assessment Years 1974-75 and 1975-76. Following the said order, the High Court disposed of R.C. No. 292 of 1982 for the Assessment Years 1976-77 and 1977-78 which gave rise to Civil Appeal Nos. 9269-9270 of 1995.

2. H.E.H. the Nizam of Hyderabad created a trust with a corpus fund of Rs. 22,20,000/-, named "H.E.H. the Nizam s Pilgrimage Money Trust" on November 2, 1950. The objects of the Trust, inter alia, are that during lifetime of H.E.H. the Nizam to meet expenses of Haj Pilgrimage of himself and members of his family accompanying him on such pilgrimage and expenses on visits to holy places of Hedjaz and Iraq and also for making religious offerings at such places as the settlor in his absolute discretion might think fit; that after the death of the Nizam th