B. P. JEEVAN REDDY, J.

( 1 ) THE only question which the Revenue wants us to direct the Tribunal to refer under section 256 (2) of the Income-tax Act, 1961 ("the Act") is :"whether, on the facts and in the circumstances of the case, the Appellate Tribunal is correct in law in holding that the assessee is not liable to wealth-tax after the introduction of section 21aa in the Wealth-tax Act, 1957 ?"

( 2 ) THE assessment year is 1981-82. The assessee is George Club. Section 21aa of the Wealth-tax Act, 1957 ("the Act"), was introduced by the Finance Act, 1981, with effect from 1/04/1981. At the relevant time, sub-section (1) of section 21aa read as follows :"assessment when assets are held by certain associations of persons.- Where assets chargeable to tax under this Act are held by an association of persons, other than a company or co-operative society and the individual shares of the members of the said association in the income or assets or both the said association on the date of its formation or at any time thereafter are indeterminate or unknown, the wealth-tax shall be levied upon and recovered from such association in the like manner and to the same extent as it would be leviabl

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