JUDGMENT

Braund, J. - This is a case referred to us u/s 66(1), Income Tax Act, 1922, by a strong Bench of the Income Tax Appellate Tribunal. The assessee is Rani Amrit Kunwar Sahiba, hereinafter referred to as 'the Rani.' The Rani is the wife of Raja Ravi Sher Singh Bahadur, the Ruler of Kalsia State, and is the sister of His Highness the present Maharaja of Nabha State. Kalsia and Nabha States were formerly part of what were known as the Cis-Sutlej States, which are now under the superintendence of the Agent to the Governor-General, Punjab States.

2. The Rani for some years past has lived at Dehradun in British India with her sons and daughters who are being educated there and it is common ground that in the year of assessment she was resident in British India within the meaning of Section 4A, Income Tax Act, 1922. The relevant accounting year is 1938-39; and the relevant assessment year is 1939-40. In the assessment year, the Rani received at Dehradun a sum of Rs. 14,744 from Kalsia State and a sum of Rs. 8910 from Nabha State. On the facts as they have been found by the Income Tax Tribunal it may be taken that similar payments had been made to the Rani of varying amounts in each o