JUDGMENT

TULZAPURKAR, J.:— The common question of law that arises for our determination in these appeals is :

Whether on the facts and in the circumstances of the case, the right or interest of an assessee in an annuity policy is exempt from wealth-tax under S. 5(1)(vi) of the Wealth-tax Act, 1957?

2. The facts giving rise to the question are briefly these. Yuvraj Amrinder Singh and Princess Rupinder Kumari are individual assessee being assessed to wealth-tax under the Wealth-tax Act, 1957 (hereinafter called the Act). As regards the former the two assessment years are 1964-65 and 1965-66 for which the respective valuation dates are 31-3-1964 and 31-3-1965, whereas the assessment year in the case of Princess Rupinder Kumari is 1965-66 for which the valuation date is 31-3-1965. The two assessees had purchased one annuity policy each and they claimed exemption in respect of the value of each policy in each ones assessment to wealth-tax under S. 5(1)(vi) of the Act. The value of the annuity policy in the case of Yuvraj Amrinder Singh was Rs. 2,13,000/- while in the case of Princess Rupinder Kumari it was Rs. 2,35,176/- Exemption in respect of such value was claimed under S. 5(1)(vi) of