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5. On perusal of the impugned order, we find that the CIT(A) had relied on the decision of Stock Exchange Ahmedabad vs ACIT, reported in 248 ITR 209 (SC), wherein, the Hon'ble Supreme Court after referring to the rules of Stock Exchange, and held, "that the right of 3 Executors of the Estate of Keshavdev R. Ganeriwala member of the stock exchange was not a private asset. It was merely a personal privilege granted to a member. It was non transferable and incapable of alienation by the member on his legal representatives except to the limited extent provided in the rules and subject to fulfillment of conditions. The nomination wherever provided was not automatic but hedged in by rules. On the right of nomination vesting in the stock exchange under rules, that belonged to the stock exchange absolutely. In the case of death or default of a member, his right of nomination ceased and vested in the stock exchange. The membership right or membership card of the said member was not his property and therefore could not be attached u/s 281B and since no amount on account of the said member was due or held by the stock exchange, section 226(3) could not be invoked". To arrive at this decision, the Hon'ble Apex court referred to earlier decisions, in the case of official Assignee of Bombay Vs. KRP Shroff 1932 AIR 186 (PC) and Vinay Bubna vs. Stock Exchange 97 Company Cases 874 (SC), wherein it was held, "that the membership of the stock exchange is a personal permission from the stock exchange to exercise the rights and privileges attached thereto. The said right is not a private asset".