JUDGMENT - 1. We are concerned in this reference with the assessment of the trustees of the Putlibai R. F. Mulla Trust to wealth-tax for years 1957-58, 1958-59 and 1959-60. The relevant valuation dates are March 31, 1957, March 31, 1958, and March 31, 1959.

2. The trust was declared on the 14th of September, 1931, by Putlibai R. F. Mulla for the benefit of herself, her children and their spouses and her grandchildren. The relevant clauses of that trust are clauses (c) to (g), both inclusive, and are, for convenience of reference, reproduced below :

"(c) During the lifetime of the settlor and her husband to divide the net rents, profits, interest dividend and income (hereinafter for brevitys sake referred to as the net income) into six equal parts and to pay one equal part to the settlor and to divide the remaining five parts amongst the settlors children in equal shares until the time hereinafter mentioned.

(d) In case the settlor predeceases her husband, then on the death of the settlor to hand over the trust properties to the settlors husband absolutely and as the absolute owner thereof.

(e) In case the settlor survives her husband to pay the whole of the net income to the settlo

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