R.D. Agrawala, Judicial Member - (1.)THESE are two appeals preferred by the revenue pertaining to the wealth-tax assessment of the assessee, by status an individual for the assessment years 1973-74 and 1974-75 wherein the following two identical grounds have been taken:
(1) The learned CIT(A) failed to note that the valuation adopted by the WTO was supported by reports obtained under Section 16A of the WT Act from Valuation Officer.

(2) "The learned CIT(A) erred in her direction that value adopted in other co-owners' cases (where valuation was not made under Section 16A should be adopted in the assessee's case as well, and since it is tantamount to ignoring valuation obtained under Section 16A, such a direction is bad in law.

(2.)We have heard the learned representatives on both the sides.
The case involves the valuation of the assessee's share in two properties, one situated at Tilak Road and, the other at Khairatabad. The assessee showed the valuation of Tilak Road property at Rs. 50,000 and Rs. 46,430 in both of which she has 1/7th share. As per the Wealth-tax Officer both these properties were also valued by the Valuation Officer, Unit-I of the Income-tax Department who determined the value of these properties at Rs. 10,75,000 and Rs. 8,85,000 respectively as on 31-3-1973. This brings the assessee's share at Rs. 1,53,571 and Rs. 1,26,740.

(3.)IN the first appeal, the following grounds were raised by the assessee:
(i) No reference under Section 16A of the WT Act was made by the Wealth-tax Officer before whom the assessee's case was pending,

(ii) IN the case of Smt. Bader Banu and Smt. Sayeeda Banu, co-owners, the returned value of l/7th share in both these properties for the assessment year 1973-74 was accepted by the respective WTOs vide their orders dated 22-1-1984 and 7th April, 1976, and

(iii) Even in the case of Smt. Farida Banu where the actual reference under Section 16A was made and the report of the Valuation Officer obtained, the returner value was accepted for the assessment year 1973-74 by the Wealth-tax Officer, B-Ward, Circle-III, Hyderabad vide order dated 13-12-1974.