JUDGMENT

Abhay Manohar Sapre, J.

1. This appeal is filed against the final order dated 26.03.2014 passed by the High Court of Rajasthan at Jaipur in D.B. Income Tax Reference No. 64 of 1986 relating to the Assessment Year 1978-79 whereby the Full Bench of the High Court answered the question of law referred to it against the appellant herein.

2. In order to appreciate the issue involved in the appeal, it is necessary to state the relevant facts in brief infra.

3. The appellant was the Ruler of the princely State of Kota, now a part of State of Rajasthan. He owned extensive properties which, inter alia, included his two residential palaces known as "Umed Bhawan Palace" and “City Palace”. The appellant is using Umed Bhawan Palace for his residence. So far as this appeal is concerned, the issue involved herein centers around "Umed Bhawan Palace".

4. In exercise of the powers conferred by Section 60A of the Indian Income Tax Act, 1922 (XI of 1922), the Central Government issued an order called "The Part B States (Taxation Concessions) Order, 1950" (hereinafter referred to as "The Order"). It was issued essentially to grant exemptions, reductions in rate of tax and the modifications in r