KANAKARAJ, J.

All the above writ petitions have been filed by the Thanthi Trust and more or less raise a common question and they can be disposed of conveniently by a common order By an instrument of declaration of trust, dated March 1, 1954, the Tamil newspaper Daily Thanthi was established as an organ of educating the public and disseminate news on all matters of public interest through the said newspaper. The claim of the trust for exemption under section 4(3) of the Indian Income-tax Act, 1922, had been upheld for the assessment years 1955-56 to 1961-62. By a supplementary deed, dated June 28, 1961, the founder of the trust directed that the surplus income of the said trust, after defraying all the expenses should be devoted, by the trustees for establishing certain educational institutions, providing scholarships for students and for running orphanages. In a Civil Suit No. 90 of 1961, by judgment dated March 2, 1962, it was held that the trustees were bound by the supplementary document to utilise the surplus funds of the Thanthi Trust for the educational purposes mentioned in the supplementary document. For the assessment year 1968-69, the trust claimed exemption under section 11 of the Income-tax Act on the ground that seventy per cent. of the income had been applied for charitable purposes. A similar claim was made for the assessment year 1969-70. The claim of exemption was denied for the assessment years 1968-69 and 1969-70. The trust filed appeals and even while the appeals were pending, an attempt was made to reopen the assessments for the earlier years 1956-57 to 1961-62 as also 1965-66 and 1967-68. By judgment dated December 21, 1972, the reopening of the assessment for the earlier years was held to be invalid, so far as the assessment years 1956-57, 1958-59, 1960-61 and 1961-62 in the writ petitions filed by the trust. However, the reopening of the assessments for the years 1957-58, 1959-60, 1965-66, 1966-67 and 1967-68 were held to be valid, subject to certain conditions. The said judgment is in Thanthi Trust v. ITO 1973 (91) ITR 261 (Mad). In respect of the appeals preferred for the assessment years 1968-69 and 1969-70, the matter went up to the High Court and by judgment dated January 29, 1981, all the questions were answered in favour of the petitioner, holding that the petitioner-trust is a public charitable trust and can claim the exemption under section 11 of the Income-tax Act. Therefore, it is contended by the petitioner-trust that it is by now well-settled that the petitioner is a public charitable trust within the meaning of the Income-tax ActThe above narration relating to the assessments under the income-tax, are relevant for the purpose of the wealth-tax, with which alone we are concerned in all the present writ petitions, only for a limited purpose, viz., that section 5(1) of the Wealth-tax Act says that any property held by a person under trust or other legal obligation for any public purpose of a charitable or religious nature, is not assessable to wealth-tax. We will now refer to the history of the case in relation to the respective wealth-tax assessments. For the assessment years 1977-78, 1978-79 and 1980-81, the Wealth-tax Officer held that the petitioner-trust was not liable for assessment. For the assessment year 1982-83, a notice was issued on October 7, 1982, calling upon the petitioner to file a return under section 14(2) of the Wealth-tax Act. A similar notice was also issued for the assessment year 1983-84 on September 13, 1983. The petitioner sent replies on November 16, 1982, and January 10, 1983, contending that it was not liable to pay the wealth-tax since it had already been adjudicated that the petitioner is a public charitable trust. However, the petitioner filed "nil" returns for the abovesaid two years. The respondent proceeded to issue notice on January 22, 1987, under section 16 of the Wealth-tax Act, calling upon the petitioner to attend an enquiry with regard to