( 1 ) THIS reference, under Section 27 (1) of the Wealth-tax Act, 1957, has been made in the circumstances hereinafter related.

( 2 ) FOR the assessment year 1957-1958 (the relevant valuation date being December 31, 1956) the Wealth-tax Officer assessed the assessee Sm. Champa Kumari Singhi, in respect of family assets, in the status of a Hindu Undivided Family. Against the order of assessment, the assessee appealed before the Appellate Assistant Commissioner and, inter alia, contended. (1) that regard being had to the description of the assesses in the notice of demand, as Champa Kumari Singhi and ors. , the assessee should be deemed to nave been treated as an association of persons and that such a unit was not chargeable to tax under the Wealth-tax Act. (2) that the assessee being a member of a Jain family could not be treated as a Hindu Undivided Family. (3) that even if the assessee be treated as a Hindu Undivided Family the imposition of Wealth-tax on a Hindu Undivided Family was ultra vires the Constitution.

( 3 ) THE Appellate Assistant Commissioner negatived all the three contentions with the following observation :--"as regards the objection regarding the d