Judgment

S.C. AGRAWAL, J.

(1) THESE appeals, by certificate granted by the High court under S. 29(1 of the Wealth Tax Act, 1957, (hereinafter referred to as the Act) are directed against the judgment of the High court of Allahabad dated 2/02/1982 in Wealth Tax Reference No. 179 of 1978.

(2) THE appellant, F.S. Gandhi (hereinafter referred to as the assessee), owns properties situate at Mahatma Gandhi Marg and Sardar Patel Marg in Civil Lines area at Allahabad. The lands on which these buildings stand were leased out to the assessee by the government of Uttar Pradesh. The leases in respect of these properties, except the property situate at 30-A, Mahatma Gandhi Marg, expired in 1958 and the lease in respect of the property situate at 30-A Mahatma Gandhi Marg expired in 1963. The government of Uttar Pradesh issued notices to the assessee to hand over vacant possession of the leasehold lands. The properties are let out to the tenants and the assessee was receiving rental income from the same. For the assessment years 1971-72, 1972-73, 1973-74 and 1974- 75 the assessee submitted the wealth tax returns wherein he valued the properties at ten times of the annu