R.S.Narula, J.

1. The circumstances in which the following question of law has been referred to this court by the Income-tax Appellate Tribunal, Delhi Bench "A", at the instance of the Commissioner of Wealth-tax, Punjab, Patiala, under Section 27(1) of the Wealth-tax Act (27 of 1957) (hereinafter called "the Act"), may first be noticed :

"Whether, on the facts and in the circumstances of the case, the two lands in question were agricultural lands within the meaning of Section 2(e)(i) of the Act on the valuation date ?"

2. Shrimati Sheela Devi, respondent, hereinafter referred to as the assesses, owned two plots of land on either side (one on the east and the other on the west) of the central plot which originally belonged to her but had been sold by her earlier to the Government for establishment of Government postal colony. The relevant assessment year is 1961-62, and the relevant valuation date is March 31, 1961. The pivotal question around which the present dispute revolves is whether on the valuation date these two plots of land were or were not agricultural land within the meaning of Section 2(e)(i) of the Act. If those were agricultural land, as held by the Tribunal,