K.S.Hegde, J.

(1) THIS appeal by certificate arises out of the wealth-tax assessment of the assessee-respondent, an individual, for the year 1959-60 the corresponding valuation date being 31/03/1959. The assessed is the wife of Maharaja of Jaipur. On 9/09/1953, the Maharaja made a settlement at London. Under the deed of settlement, he appointed Sir Harold Augustus Warner as the trustee of the property detailed in the deed of settlement. The settlement is an irrevocable one and the properties mentioned in the schedule to the trust deed stood transferred to the name of the trustee, The trust deed provides that the trustee should pay to the assessee during her life time 50 per cent of the income of the trust fund. The question arose whether the assessee can be held to have any share in the corpus of the trust and whether the same can be brought to tax under the provisions of the Wealth Tax Act, 1957 (to be hereinafter referred to as the Act), The Wealth Tax Officer came to the conclusion that the assessees interest in U.K.. Trust amounting to Rs. 15,75,694.00 plus the income-tax reserve thereon Rs. 1,75,401.00 have to be included in the assessees total wealth. Thi