Judgment

HEGDE, J.:- Civil Appeals Nos. 1429 and 1430 of 1971 are by special leave and Civil Appeals Nos. 2385 and 2386 of 1969 are by certificate. The latter appeals have become infructuous as the certificates by which they have been brought are not supported by any reason. Hence the appellants had to apply and obtain special leave from this court for appealing against the judgment of the High Court. Civil Appeals Nos. 1429 and 1430 have been brought on the strength of the special leave granted by this court. These are the appeals which we have to consider now.

2. All these appeals arise from the decision of the Bombay High Court in a reference under Section 27 of the Wealth Tax Act. 1957. The question referred to the High Court reads:

"Whether on the facts and in the circumstances of the case, and having regard to the terms of Annexure "A" the Tribunal was justified in holding that the interest of the assessee under the Trust had no value?

3. The relevant portion of the Trust deed which came up for consideration by the Tribunal as well as the High Court reads thus:

"2. The trustees shall hold and stand possessed of the Trust found up on trust :-

(a) x x x x

(b) To apply the balance of s