Y. V. ANJANEYULU, J.

( 1 ) ALL the four references under section 27 (1) of Wealth-tax Act, 1957, are at the instance of the Commissioner of Wealth-tax. An identical question of law is referred to this court in all the four references. The facts in all the four cases are also identical. It will, therefore, be convenient to dispose of all the four references together by a common judgment.

( 2 ) ONE Sri A. V. Reddy of Kadiam in East Godavari District (hereinafter referred to as "the settlor") created four trusts for the benefit of his three grandchildren and a daughter. One trust was created for the benefit of his grandson, Dexter Anand Sear (eldest son of his daughter, Margaret ). The relevant trust deed was executed on 14/03/1972, and is the subject-matter of consideration in R. C. No. 37 of 1983. The name of the trust is misdescribed by the tax authorities as well as the Tribunal. It is referred to as "sri A. V. Reddy Trust for Mrs. Margaret Anne Reddy", whereas the trust deed would indicate that the trust was created in favour of Dexter Anand Sear, the settlors daughters son. Another trust was created on 3/10/1970, for the benefit of the settlors grandson, Harish Reddy, and the tr

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