- (1.) Heard Shri Shambhu Chopra, learned Counsel for the Department. Shri S. D. Singh appears for the Respondent-Assessee.
(2.) In this wealth-tax appeal filed Under Section 260A of the Income-tax Act, 1961 the Commissioner of Income-tax, Kanpur, has posed a question of law to be decided by the High Court: Whether the hon'ble Income-tax Appellate Tribunal, in view of Rule 14(2)(b) of Part D of Schedule III to the Wealth-tax Act was justified in holding that the value of the properties should have been taken at the book value as these properties were business assets, without appreciating the fact that the fair market value of these properties was higher by more than 20 per cent. of its book value and as per Rule 14(2)(b) read with Rule 20 their fair market value should have been adopted for the wealth-tax purposes ?
(3.) The delay of 23 days in filing the appeal has been sufficiently explained, and is accordingly condoned. Since the matter is pending in this Court for the last ten years, we have heard the appeal on the merits.;