K.S. Hegde, J. - (1.) These are appeals by special leave. The question for decision in these appeals is whether the goods in transit from England to India belonging to a non-resident assessee can be considered as wealth of the assessee during the relevant valuation dates. The relevant assessment years are 1957-58, 1958-59 and 1959-60.
(2.) The assessee is admittedly a non-resident company. It is said that during the relevant valuation dates some goods belonging to the assessee were on the High Seas. The question for decision is whether the value of those goods can be taken into consideration in computing the net wealth of the assessee.
(3.) Section 3 of the Wealth-tax Act, 1957, is the charging section. That section says: Subject to the other provisions contained in this Act, there shall be, charged for every assessment year commencing on and from the first day of April, 1957, a tax (hereinafter referred to as 'wealth tax') in respect of the net wealth on the corresponding valuation date of every individual, Hindu undivided family and company at the rate or rates specified in. the Schedule.;