Hon’ble Sudhir Agarwal, J.—We have heard Shri Shubham Agrawal, learned counsel for the appellant and Shri S.D.Singh, learned Senior Counsel for respondent.

2. These appeals under Section 27-A of Wealth Tax Act, 1957 (hereinafter referred to as ‘Act, 1957’) have arisen from judgment and orders dated passed by Income Tax Appellate Tribunal Lucknow Bench, Lucknow (hereinafter referred to as ‘Tribunal’).

3. WTA Nos. 68 of 2007, 206 of 2012, 579 of 2011, 204 of 2012, 576 of 2011, 575 of 2011, 578 of 2011, 205 of 2012 were admitted on following two substantial questions of law:

“(i) Whether ITAT were justified in holding that certain provisions of building bye laws framed by J.D.A in Jan, 1996 were to apply retrospectively for Wealth Tax assessment on valuation date 31.3.1987.

(ii) Whether ITAT were justified in holding that a certain provision of bye laws of J.D.A of Jan, 1996 were to apply in the case of Assessee when this bye laws has itself excluded case of properties like that of Assessee where construction according to sanctioned plan has already been made.”

4. In remaining appeals, i.e W.T.A Nos. 292 of 2012, 295 of 2012, 294 of 2012, 241 of 2012, 169 of 2005, 395 of 2012 and 194 of 2006 substantial questions of law are similar above questions but differently worded and read as under:

“1. Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was correct in law in holding that since the regulations of J.D.A were to be operative retrospectively, the assessee was justified in claiming that in view of the Explanation to Rule 6 read with the relevant J.D.A Regulation, the specified area was to be worked out and as such Rule 8(b) read with Rule 20 shall not be applicable?

2. Whether on the facts and in the circumstances of the case, the view taken by the Income Tax Appellate Tribunal that by virtue of Explanation to Rule 6 of the Schedule III of the Wealth Tax Act, 1957 being applicable retrospectively, the Notification GSR-29 dated 25.6.1996 issued by the Jaipur Development Authority will also have retrospective effect, is correct in law?”

5. The above appeals relate to different assessment years. Details of appeals, relevant assessment years, date of Tribunal’s judgment and appeal details in Tribunal, are as under:

S.N.	Wealth Tax Appeal No.	Assessment year	Date of order of Tribunal	Wealth Tax Appeal No. before Tribunal
1.	68 of 2007	1987-88	29.11.2001	37/Alld/2000
2.	575 of 2011	1988-89	6.7.2004	14/Luc/2002
3.	292 of 2012	1989-90	6.7.2004	29/Luc/2002
4.	576 of 2011	1990-91	6.7.2004	22/Luc/2002
5.	205 of 2012	1991-92	6.7.2004	23/Luc/2002
6.	295 of 2012	1992-93	6.7.2004	24/Luc/2002
7.	578 of 2011	1993-94	6.7.2004	25/Luc/2002
8.	294 of 2012	1994-95	6.7.2004	26/Luc/2002
9.	204 of 2012	1995-96	6.7.2004	27/Luc/2002
10.	579 of 2011	1996-97	6.7.2004	28/Luc/2002
11.	241 of 2012	1997-98	6.9.2004	16/Luc/2000
12.	206 of 2012	1998-99	6.7.2004	15/Luc/2002
13.	169 of 2005	1999-2000	6.7.2004	30/Luc/2005
14.	194 of 2006	2000-01	6.11.2005	03/Luc/2002
15.	395 of 2012	2001-02	6.11.2005	04/Luc/2005

6. Assessee, (late) Shri Padampat Singhania, through legal heir Dr.Gaur Hari Singhania, (hereinafter referred to as ‘Assessee’), is owner of ‘Jaipur House’ at Jaipur. From the record and in particular, para 5.2 of the assessment order dated 31.3.1999, passed in relation to assessment year 1987-88, it is evident that the house in question was constructed much before August 1964, since it was the case set up on behalf of Assessee that the disputed property was leased out to a company and in this regard minutes dated 28.8.1964 were relied. Hence construction of house is very old and at least in 1964 it was in existence. Thereafter, there was any addition/alteration in