JUDGMENT

Mrs. SUJATA V. MANOHAR, J.:—These appeals by special leave arise from a common judgment of the High Court of Orissa in seven Reference Applications before it under Section 27(1) of the Wealth-tax Act, 1957. The High Court was required to consider the following question (1976 Tax LR 978, Para 1) :-

"Whether the word jewellery in Section 5(1)(viii) of the Wealth-tax Act. 1957 prior to the amendment of the section and the introduction of the Explanation by the Finance Act (No. 2) of 1971 could take in gold ornaments without precious or semi-precious stones embedded on them?"

The High Court has answered the question thus (1976 Tax LR 978, Para 4):-

"The word jewellery in Section 5(1) (viii) of the Wealth-tax Act of 1957 prior to amendment of the provision and introduction of Explanation I by the Finance Act (No. 2) of 1971 would not take in gold ornaments without precious or semi-precious stones embedded on them."

The Commissioner of Wealth Tax has filed the present appeals from the above decision.

2. The relevant assessment years are 1965-66 to 1971-72. The relevant valuation dates are 31st of March of each of the years in question. We are therefore, required to consider the provi