D.M. Chandrashekhar, CJ.

1. IN these three references under Section 27 of the Wealth-tax Act, 1957 (hereinafter referred to as "the Act"), the following common question of law has been referred to this court by the INcome-tax Appellate Tribunal (hereinafter referred to as "the Tribunal" ):

"Whether, on the facts and in the circumstances of the case, the INcome-tax Appellate Tribunal was justified in holding that Rules 1C and ID introduced by the Wealth-tax (Amendment) Rules, 1967, by notification dated October 6, 1967, do not have any retrospective effect and could not be applied for the valuation of the unquoted shares for the assessment years in question as the relevant valuation dates thereof preceded October 6, 1967?"

2. EACH of these references relates to a separate assessee, but in respect of the same assessment years, i.e., 1965-66 and 1966-67. In each of these cases the assessee had valued for the purpose of wealth-tax certain shares which had not been quoted in the stock exchange, by adopting the average of the break-up value thereof and the average yield of dividends therefrom. The Wealth-tax Officer valued these shares on the basis of their break-up value only. But