( 1 ) THE relevant facts in this reference under Section 27 (1)of the Wealth-tax Act, 1957, as appearing from the statement of the case and the annexures thereto may be shortly stated as follows: the assessee in the instant case held certain shares of Martin Burn Co. Ltd. during the assessment year 1965-66, On the 26th March, 1965, Martin Burn Co. Ltd. , at its annual general meeting, declared dividends. The relevant resolution in respect of such declaration was as follows :"that for the year ended 30th September, 1964, a total dividend of Rs. 2. 50 per share on the ordinary share capital of the company be and is hereby declared out of the general reserve of the company and that out of the said dividend an interim dividend of Re. 1 per ordinary share having been declared by the directors and already paid to shareholders on the 1st October, 1964, which is hereby confirmed, the balance of Rs. 1. 50 per ordinary share be paid to those shareholders whose names appear in the company's register of members on the 26th March, 1965, or to their mandates on and after the 1st April, 1965. "

( 2 ) IT is not disputed that the net dividend payable to the assessee in terms of