1. The Income-tax Appellate Tribunal, Cochin Bench (hereinafter called the Tribunal) has referred the following two questions to this court under S.27 (1) of the Wealth-tax Act, 1957 (hereinafter called the Act):

"(i) For an asset to be included either under S.4(1)(a)(i) or, as the case may be 4 (1) (a) (ii) of Wealth tax Act, 1957 in the net wealth of the assessee for assessment year 1970-71 or assessment year 1971-72. whether that asset should also be an asset within the definition of that term asset in Wealth-Tax Act, 1957 as it applied at the time that asset was transferred by the assessee?

(ii) Whether the expression 'assessment year commencing after the 31st day of March, 1964' appearing in the proviso to S (4) (1) (a) of Wealth-tax Act, 1957 as it applied to assessment years 1970-71 and 1971-1972 refers to wealth-tax assessment year?"

2. The aforesaid questions have arisen in relation to the assessments to wealth-tax made against the assessee for the assessment years 1970-71 and 1971-72 for which the valuation dates are 31st March, 1970 and 31st March, 1971 respectively In making those assessments the Wealth-tax Officer acting under S.4 (1) (a) (i) and (ii) of the A