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Issues:
1. Inclusion of trust properties in the wealth of the assessee for wealth-tax assessment. 2. Interpretation of section 4(1)(a)(iii) of the Wealth-tax Act, 1957 regarding the benefit contemplated. Analysis: The judgment addressed the issue of including trust properties in the wealth of the assessee for wealth-tax assessment. The assessee, a Maharaja, created a trust for the benefit of his family. The Wealth-tax Officer proposed to include the trust properties in the wealth of the assessee, but the Appellate Assistant Commissioner disagreed. The Tribunal also ruled against including the trust properties based on section 4(1)(a)(iii) of the Wealth-tax Act, 1957. This section requires assets transferred without adequate consideration for the immediate or deferred benefit of the individual, spouse, or minor child to be included in net wealth. The trust properties were transferred solely for the benefit of the family, including the assessee, as per the trust deed. The judgment delved into the interpretation of section 4(1)(a)(iii) regarding the benefit contemplated. The court analyzed the nature of benefits, including material and spiritual benefits, and the scope of the section. It highlighted that the trust properties were held for the benefit of the family, not specifically for the individual, spouse, or minor child as required by the section. The court emphasized that the section's application is limited and does not extend to benefits for entities outside those mentioned in the provision. Additionally, the judgment discussed the applicability of the principle of estoppel or res judicata based on past practices of not including trust properties in previous assessments. Ultimately, the court ruled in favor of the assessee, stating that section 4(1)(a)(iii) was not applicable, and the trust properties should not be included in the wealth assessment. The second question regarding the type of benefit under the section was deemed unnecessary to answer based on the first question's outcome.
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