1. This is a reference under Sec.27(1) of the Wealth-tax Act, 1957 (hereinafter called "the Act"). The question referred for our opinion is whether a cold storage is "an industrial undertaking" and reads as follows :

"Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that cold storage is also a plant and comes under an industrial undertaking and is entitled to statutory exemption as provided under Sec. 5(1)(xxxii) of the Wealth-tax Act, 1957 ?"

2. In this reference, we are concerned with the assessment year 1973-74, The assessee is an individual. She (for, the assessee is a lady) had invested large amount in a firm, M/s Vishnu Cold Storage. The value of her holdings was to the tune of Rs. 1,50,000. The Wealth-tax Officer intended to include the value of her holdings in the cold storage for the purpose of reckoning her liability under the Act. The assessee contended that her interest in the cold storage was not liable to be included in terms of Sec. 5(1)(xxxii) of the Act. The Wealth-tax Officer rejected her claim. She, however, succeeded before the Appellate Assistant Commissioner and the Appellate Tribunal. Hence, the re