JUDGMENT

R.M. Lodha, J.:- Leave granted in the special leave petitions.

2. This is a group of 17 Appeals — 8 arising from the Income Tax Act, 1961 and 9 arising from the Wealth Tax Act, 1957. Of the 9 Wealth Tax appeals, one appeal relates to 'protective assessment' for 18 assessment years, i.e, 1970-71 to 1976-77, 1978-79 to 1979-80, 1981- 82 to 1989-90. The remaining 8 Wealth Tax appeals relate to assessment years 1970-71, 1971-72, 1972-73, 1973-74, 1974-75, 1975-76, 1976-77 and 1978-79. In so far as 8 appeals arising from the assessment orders passed under the Income Tax Act, 1961 are concerned, they relate to assessment years 1984-85, 1985-86, 1986-87, 1987-88, 198889, 1989-90, 1990-91 and 1991-92.

3. The ex-Ruler of Gondal Shri Vikramsinhji executed three deeds of settlements (trust deeds) in the United States of America on December 19, 1963 and two deeds in the United Kingdom on January 1, 1964. The three settlements executed in U.S. are in identical terms. Similarly, the two settlements executed in U.K. are similar.

4. In the course of arguments, it was conceded by the learned counsel for the Revenue that in view of the decision of this Court in Commissioner of Income Tax,