Per Shri S.K. Chander, Accountant Member - These appeals by the Revenue are directed against the orders of the AAC for the asst. years 1975-76, 1978-79 and 1981-82. All these orders are made by the learned AAC on 5-9-1984. However, the main speaking order is made the year 1975-76. From both the sides, the parties agreed that arguments for the asst. year 1975-76 shall apply mutatis mutandis to other years and our decision, in this case, for this year, will cover the wealth-tax assessments for the asst. years 1974-75 and 1975-76. We have, therefore, heard the parties, in this case and proceed to decide the issues brought in appeal before us.

2. The assessee before us is a trust known as Mrs. Dwarika Prasad Trust, 56 Civil Lines, Bareilly. This trust was created by late Shri Girish Prasad by will dated 15-8-1972, registered on 3-4-1973. After making the will, but before registration, the settlor died on 22-1-1973. But the Trust was to take effect from the date of his death. The Trust was for charitable purposes. There is no dispute that but for clause (d) in the will, the other provisions were considered by the ITO as charitable in character. However, with regard to clause (d) in