Judgment

HEGDE, J.: - These appeals by certificate under section 29 of the Wealth Tax Act, 1957 (to be hereinafter referred to as the Act) arise from a reference under section 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 questions of law viz (1) whether under the three trust deeds referred to therein the assessee got annuities falling within the scope of section 2 (e) (iv) ? and (2) whether the value of the jewels owned by the assessee was exempt under section 5 (1) (viii) in computing the net wealth of the assessee?

2. The assessee 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 assessee 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 assesse. By another deed of settlement dated October 12, 1945 he settled certain other shares upon trust for the benefit o