( 1 ) THIS Reference under sec. 27 (1) of the Wealth Tax Act 1957 raises some interesting and important questions relating to the construction of sec. 2 (m) and sec. 7 of the Wealth Tax Act which have been argued with considerable vigour and ability by both the sides. One of the noteworthy features of this case is that some cases have been relied upon by both the sides in order to deduce contrary conclusions. The Raipur Manufacturing Company Limited is the assessee in this case. The assessment year in question is the year 1957-58 the relevant valuation date being the 31st December 1956. On 11th May 1956 a demand notice had been issued on the assessee under sec. 18-A of the Indian Income-Tax Act 1922 for advance payment of tax requiring the Company to pay a sum of Rs. 3 59 549 in four instalments the instalments being payable on the 15th June 1956 the 15th September 1956 the 15th December 1956 and the 15th March 1957. Prior to the valuation date the assessee paid the three instalments payable on the 15 June 1956 the 15th September 1956 and the 15th December 1956. On the 31st December 1956 the fourth instalment of Rs. 89 889 had remained unpaid the same being payable o