( 1 ) THIS revision is placed before us on a reference made by our learned brother, Muktadar, J. , by order dated 29th Jan. , 1981 as an important question of law is involved in the matter.

( 2 ) THE parties are described in this judgment as they were arrayed in the petition. The facts relevant for disposal of this revision are as follows: Sahebzadi Fatima Fouzia and Sahebzadi Amina Marzia, the grand-daughters of His Exalted Highness the Nizam, are respondents 1 and 2 in the petition. The 3rd respondent is the Wealth Tax Officer, Central Circle III, Hyderabad.

( 3 ) HIS Exalted Highness the Nizam VII of Hyderabad executed on 4th Sept. , 1951 an Indenture of Trust known as "wedding Gifts Trust of H. E. H, the Nizams two grand-daughters" whereby he settled jewellery and ornaments specified in the first and second schedules and 3 per cent Government of India securities of the face value of Rs. 50,000, Rs. 1,25,000, Rs. 1,25,000 and Rs. 25,000 specified in the third, fourth, fifth and sixth schedules to the deed of trust respectively for the benefit of his two grand-daughters Sahebzadi Fatima Fouzia and Sahebzadi Amina Marzia, respondents 1 and 2. The petitioners and Pr