( 1 ) AT the instance of the Revenue, the following question has been referred under Section 27 (1)of the Wealth-tax Act, 1957 : " Whether, on the facts and in the circumstances of the case, the Tribunal was correct in holding that the firm in which the assessee was a partner was an industrial undertaking within the meaning of the Explanation to Section 5 (1) (xxxi) of the Wealth-tax Act, 1957, and was entitled to exemption under Section 5 (1) (xxxii) of the Wealth-tax Act, 1957 ?"

( 2 ) THE respondent assessee is an individual and the valuation date for each assessment was the last date of the relevant calendar year. The assessee is a partner in a registered firm, M/s. Indian cold Storage and Industries Co. , Meerut, which carries on the business of running cold storage and also manufactured ice. In respect of his interest in the aforesaid firm amounting to Rs. 87,686 for the assessment year 1973-74 and the valuation of his interest in the said firm for the subsequent year 1974-75 being Rs. 96,006, the assessee claimed exemption under Section 5 (1) (xxxii) of the Wealth-tax Act on the ground that the firm, M/s. Indian Cold Storage and industries Co. , Meerut, was