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TMI Blog1991 (3) TMI 80X X X X Extracts X X X X X X X X Extracts X X X X ..... re are as many as eleven questions raised by the assessee as questions of law, the real questions are only three. According to him, questions Nos. 1 to 4 relate to the direct assessment on the beneficiaries in terms of section 21(2) of the Wealth-tax Act, 1957. Questions Nos. 5 and 6, he stated, have become infructuous in view of the Tribunal's order on the assessee's Miscellaneous Application No. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ax Officer having already exercised the option of assessing the trustees direct, it was not open to the Wealth-tax Officer to thereafter make assessments on the beneficiaries. As regards the valuation of the assessee's interest in the immovable property, he pointed out that over the years, this property was let out for a paltry sum of Rs. 315 per month. The tenant was a protected one. No doubt thi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he provisions of subsection (1) of section 21. As regards the second set of questions, however, i.e., questions Nos. 7 to 11, we are inclined to hold that the matter requires a closer examination. Accordingly, we make the rule absolute with regard to questions Nos. 7 to 11. However, we will reframe the question of law as under : "Whether, on the facts and in the circumstances of the case, the Tr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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